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Statement of Federal Financial Accounting Standards 4:

Managerial Cost Accounting Standards and Concepts

Status

Summary

The managerial cost accounting concepts and standards contained in this statement are aimed

at providing reliable and timely information on the full cost of federal programs, their activities,

and outputs. The concepts of managerial cost accounting contained in this statement describe

the relationship among cost accounting, financial reporting, and budgeting. The five standards

set forth the fundamental elements of managerial cost accounting.

Managerial Cost Accounting Concepts

Managerial cost accounting should be a fundamental part of the financial management system

and, to the extent practicable, should be integrated with other parts of the system. Managerial

costing should use a basis of accounting, recognition, and measurement appropriate for the

intended purpose. Cost information developed for different purposes should be drawn from a

common data source, and output reports should be reconcilable to each other.

Managerial Cost Accounting Standards

Requirement for cost accounting - Each reporting entity should accumulate and report the costs

of its activities on a regular basis for management information purposes. Costs may be

Issued July 31, 1995

Effective Date For fiscal years beginning after September 30, 1996. Subsequently

modified to be for years beginning after September 30, 1997.

Affects None.

Affected by • SFFAS 9, Deferral of Implementation Date of SFFAS No. 4.

• SFFAS 30, Inter-Entity Cost Implementation, rescinds par. 110 and

amends par. 111 of SFFAS 4.

• SFFAS 55, Amending Inter-Entity Cost Provisions, rescinds SFFAS

30 which restored par. 110 and 111. SFFAS 55 then amends par. 110

and 111 and also added new disclosures in par. 113A.

Related Guidance • Interpretation 2, Accounting for Treasury Judgment Fund

Transactions TR 1, Audit Legal Letter Guidance

• Interpretation 6, Accounting for Imputed Intra-departmental Costs:

An Interpretation of SFFAS No. 4.

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accumulated either through the use of cost accounting systems or through the use of cost finding

techniques.

Responsibility segments - Management of each reporting entity should define and establish

responsibility segments. Managerial cost accounting should be performed to measure and report

the costs of each segment’s outputs. Special cost studies, if necessary, should be performed to

determine the costs of outputs.

Full cost - Reporting entities should report the full costs of outputs in general purpose financial

reports. The full cost of an output produced by a responsibility segment is the sum of (1) the

costs of resources consumed by the segment that directly or indirectly contribute to the output,

and (2) the costs of identifiable supporting services provided by other responsibility segments

within the reporting entity, and by other reporting entities.

Inter-entity costs - Each entity’s full cost should incorporate the full cost of goods and services

that it receives from other entities. The entity providing the goods or services has the

responsibility to provide the receiving entity with information on the full cost of such goods or

services either through billing or other advice.

Recognition of inter-entity costs that are not fully reimbursed is limited to material items that (1)

are significant to the receiving entity, (2) form an integral or necessary part of the receiving

entity’s output, and (3) can be identified or matched to the receiving entity with reasonable

precision. Broad and general support services provided by an entity to all or most other entities

generally should not be recognized unless such services form a vital and integral part of the

operations or output of the receiving entity.

Costing methodology - Costs of resources consumed by responsibility segments should be

accumulated by type of resource. Outputs produced by responsibility segments should be

accumulated and, if practicable, measured in units. The full costs of resources that directly or

indirectly contribute to the production of outputs should be assigned to outputs through costing

methodologies or cost finding techniques that are most appropriate to the segment’s operating

environment and should be followed consistently.

The cost assignments should be performed using the following methods listed in the order of

preference: (a) directly tracing costs wherever feasible and economically practicable, (b)

assigning costs on a cause-and-effect basis, or (c) allocating costs on a reasonable and

consistent basis.

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Table of Contents

Page

Summary 1

Executive Summary 4

Introduction 7

Managerial Cost Accounting Concepts 13

Managerial Cost Accounting Standards 20

Appendix A: Basis For Conclusions 47

Appendix B: Glossary [See Consolidated Glossary in Appendix E] 71

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Executive Summary

1. The managerial cost accounting concepts and standards contained in this statement are

aimed at providing reliable and timely information on the full cost of federal programs, their

activities, and outputs. The cost information can be used by the Congress and federal

executives in making decisions about allocating federal resources, authorizing and

modifying programs, and evaluating program performance. The cost information can also

be used by program managers in making managerial decisions to improve operating

economy and efficiency.

2. The concepts of managerial cost accounting contained in this statement describe the

relationship among cost accounting, financial reporting, and budgeting. The five standards

set forth the fundamental elements of managerial cost accounting: (1) accumulating and

reporting costs of activities on a regular basis for management information purposes, (2)

establishing responsibility segments to match costs with outputs, (3) determining full costs

of government goods and services, (4) recognizing the costs of goods and services

provided among federal entities, and (5) using appropriate costing methodologies to

accumulate and assign costs to outputs.

3. These standards are based on sound cost accounting concepts and are broad enough to

allow maximum flexibility for agency managers to develop costing methods that are best

suited to their operational environment. Also, the managerial cost accounting standards and

practices will evolve and improve as agencies gain experience in using them. The following

is a summary of the concepts and standards contained in this statement.

Managerial Cost Accounting Concepts

4. Managerial cost accounting should be a fundamental part of the financial management

system and, to the extent practicable, should be integrated with other parts of the system.

Managerial costing should use a basis of accounting, recognition, and measurement

appropriate for the intended purpose. Cost information developed for different purposes

should be drawn from a common data source, and output reports should be reconcilable to

each other.

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Managerial Cost Accounting Standards

Requirement for cost accounting

5. Each reporting entity should accumulate and report the costs of its activities on a regular

basis for management information purposes. Costs may be accumulated either through the

use of cost accounting systems or through the use of cost finding techniques.

Responsibility segments

6. Management of each reporting entity should define and establish responsibility segments.

Managerial cost accounting should be performed to measure and report the costs of each

segment’s outputs. Special cost studies, if necessary, should be performed to determine the

costs of outputs.

Full cost

7. Reporting entities should report the full costs of outputs in general purpose financial reports.

The full cost of an output produced by a responsibility segment is the sum of (1) the costs of

resources consumed by the segment that directly or indirectly contribute to the output, and

(2) the costs of identifiable supporting services provided by other responsibility segments

within the reporting entity, and by other reporting entities.

Inter-entity costs

8. Each entity’s full cost should incorporate the full cost of goods and services that it receives

from other entities. The entity providing the goods or services has the responsibility to

provide the receiving entity with information on the full cost of such goods or services either

through billing or other advice.

9. Recognition of inter-entity costs that are not fully reimbursed is limited to material items that

(1) are significant to the receiving entity, (2) form an integral or necessary part of the

receiving entity’s output, and (3) can be identified or matched to the receiving entity with

reasonable precision. Broad and general support services provided by an entity to all or

most other entities generally should not be recognized unless such services form a vital and

integral part of the operations or output of the receiving entity.

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Costing methodology

10. Costs of resources consumed by responsibility segments should be accumulated by type of

resource. Outputs produced by responsibility segments should be accumulated and, if

practicable, measured in units. The full costs of resources that directly or indirectly

contribute to the production of outputs should be assigned to outputs through costing

methodologies or cost finding techniques that are most appropriate to the segment’s

operating environment and should be followed consistently.

11. The cost assignments should be performed using the following methods listed in the order

of preference: (a) directly tracing costs wherever feasible and economically practicable. (b)

assigning costs on a cause-and-effect basis, or (c) allocating costs on a reasonable and

consistent basis.

12. These accounting standards need not be applied to items that are qualitatively and

quantitatively immaterial. The Board recommends that the managerial accounting standards

of this Statement become effective for fiscal periods beginning after September 30, 1996.

Earlier implementation is encouraged.

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Introduction

Background

13. Reliable information on the costs of federal programs and activities is crucial for effective

management of government operations. In Statement of Federal Financial Accounting

Concepts (SFFAC) No. 1, Objectives of Federal Financial Reporting, issued in 1993, it is

stated that the objectives of federal financial reporting are to provide useful information to

assist internal and external users in assessing the budget integrity, operating performance,

stewardship, and systems and control of the federal government.

14. Managerial cost accounting is especially important for fulfilling the objective of assessing

operating performance. In relation to that objective, it is stated in SFFAC No. 1 that federal

financial reporting should provide information that helps users to determine:

• Costs of specific programs and activities and the composition of, and changes in, those

costs;

• Efforts and accomplishments associated with federal programs and their changes over

time and in relation to costs; and

• Efficiency and effectiveness of the government’s management of its assets and

liabilities.

15. It is further stated in SFFAC No. 1 that “The topics of costs and performance measurement

are related because it is by associating cost with activities or cost objectives that accounting

can make much of its contribution to reporting on performance.”

“Cost” is the monetary

value of resources used or sacrificed or liabilities incurred to achieve an objective, such as

to acquire or produce a good or to perform an activity or service. Costs incurred may benefit

current and future periods. In financial accounting and reporting, the costs that apply to an

entity’s operations for the current accounting period are recognized as expenses of that

period.

Statement of Federal Financial Accounting Concepts No. 1, Objectives of Federal Financial Reporting (September 2,

1993), pars. 110 and 111.

Ibid., pars. 126-130.

Ibid., par. 192.

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16. The Chief Financial Officers Act of 1990 includes among the functions of chief financial

officers “the development and reporting of cost information” and “the systematic

measurement of performance.”

In July 1993, Congress passed the Government

Performance and Results Act (GPRA) which mandates performance measurement by

federal agencies.

In September 1993, in his report to the President on the National

Performance Review (NPR), Vice President Al Gore recommended an action which

required the Federal Accounting Standards Advisory Board to issue a set of cost accounting

standards for all federal activities.

Those standards will provide a method for identifying the

unit cost of all government activities.

17. In early 1994, the Federal Accounting Standards Advisory Board (the Board) convened an

advisory group to help develop standards for managerial cost accounting in the federal

government. The group included members from government, business, and academe. Their

views and proposals have been considered by the Board, and their work contributed greatly

in developing this document.

Users Of Federal Cost Information

18. The cost of government is a concern to the public as well as to the federal government itself.

Most government service efforts and accomplishments cannot be measured in financial

terms alone. Unlike private business, there is no “bottom line” or profit index to help

measure public sector performance. However, government service efforts and

accomplishments can be evaluated using both financial and non-financial measures, and

“cost” is an important financial measure for government programs. Internal and external

federal information users identified below will find these standards helpful in assessing

operating performance, stewardship, systems, and control of the federal government.

19. Government managers are the primary users of cost information. They are responsible for

carrying out program objectives with resources entrusted to them. Reliable and timely cost

information helps them ensure that resources are spent to achieve expected results and

outputs, and alerts them to waste and inefficiency.

20. Congress and federal executives, including the President, make policy decisions on

program priorities and allocate resources among programs. These officials need cost

104 Stat. 2938 (See particularly 31 U.S.C. sec 902).

107 Stat. 285 (See particularly, 31 U.S.C. sections 1101, 1105, 1115, 1116-1119, 9703, 9704).

Vice President Al Gore, Creating A Government That Works Better & Costs Less, Accompanying Report of the

National Performance Review (September 1993), p. 59.

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information to compare alternative courses of action and to make program authorization

decisions by assessing costs and benefits. They also need cost information to evaluate

program performance.

21. Citizens, including news media and interest groups, are concerned with the costs and

results of federal programs that affect their interests. They need program cost information to

judge whether resources are allocated to programs rationally and if the programs operate

efficiently and effectively.

Objectives

22. The managerial cost accounting concepts and standards presented here are intended for all

the user groups identified above. These standards are aimed at achieving three general

objectives:

• Provide program managers

with relevant and reliable information relating costs to

outputs and activities. Based on this information, program managers can respond to

inquiries about the costs of the activities they manage. The cost information will assist

them in improving operational economy and efficiency;

• Provide relevant and reliable cost information to assist the Congress and executives in

making decisions about allocating federal resources, authorizing and modifying

programs, and evaluating program performance; and

• Ensure consistency between costs reported in general purpose financial reports and

costs reported to program managers. This includes standardizing terminology for

managerial cost accounting to improve communication among federal organizations

and users of cost information.

Scope Of Standards

23. This statement contains managerial cost concepts and five standards for the federal

government. The five standards address the following topics:

(1) Requirement for cost accounting,

(2) Responsibility segments,

(3) Full cost,

Statement of Federal Financial Accounting Concepts No. 1, Objectives of Financial Reporting, defined “Program

managers” as individuals who manage federal programs, and stated that “Their concerns include operating plans,

program operations, and budget execution.” SFFAC No. 1, par. 85.

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(4) Inter-entity costs, and

(5) Costing methodology.

The essence of each standard is briefly stated in a box followed by detailed explanations.

However, both the words in the boxes and the entire text of explanations constitute

the requirements of the standards.

24. These standards are based on sound cost accounting concepts and allow sufficient

flexibility for agencies to develop managerial cost accounting practices that are suited to

their specific operating environments. Also, it is expected that cost accounting standards

and practices will evolve and improve as agencies gain experience in using them.

25. Other Statements of Federal Financial Accounting Standards (SFFAS) address recognition

and measurement of assets and liabilities. For additional guidance, readers should consult:

SFFAS No. 1, Accounting for Selected Assets and Liabilities; SFFAS No. 2, Accounting for

Direct Loans and Loan Guarantees; and SFFAS No. 3, Accounting for Inventory and

Related Property. The Board is working on and will soon complete other recognition and

measurement projects related to revenues, liabilities, property, plant, and equipment, and

other elements of financial statements.

Terminology

26. Managerial cost accounting information, to be useful, must rely on consistent and uniform

terminology for concepts, practices, and techniques. Consistent and uniform use of

terminology can help avoid confusion and mis-communication among organizations and

individuals.

27. As a start toward developing consistent managerial cost accounting terminology within the

federal government, this statement includes a glossary of basic cost accounting terms.

Materiality

28. Except as otherwise noted, the accounting and reporting provisions of these accounting

standards need not be applied to items that are qualitatively or quantitatively immaterial.

See FASAB Exposure Drafts, Accounting for Liabilities of the Federal Government (November 7, 1994); Accounting

for Property, Plant, and Equipment (February 28, 1995); and Revenue and Other Financing Sources (Pending).

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29. The determination of whether an item is material depends on the degree to which omitting

information about the item makes it probable that the judgment of a reasonable person

relying on the information would have been changed or influenced by the omission.

Effective Date

30. The managerial cost accounting standards prescribed in SFFAS No. 4 shall be effective for

fiscal periods beginning after September 30, 1997. Earlier implementation is encouraged.

Purposes Of Using Cost Information

31. There are many different purposes for which cost information may be used by the federal

government. The focus of this statement is on cost information needed to improve federal

financial management and managerial decision making.

32. In managing federal government programs, cost information is essential in the following five

areas: (1) budgeting and cost control, (2) performance measurement, (3) determining

reimbursements and setting fees and prices, (4) program evaluations, and (5) making

economic choice decisions. Each of these uses is discussed below.

Budgeting And Cost Control

33. Information on the costs of program activities can be used as a basis to estimate future

costs in preparing and reviewing budgets. Once budgets are approved and executed, cost

information serves as a feedback to budgets. Using cost information, federal managers can

control and reduce costs, and find and avoid waste. For example, with appropriate cost

information, federal managers can:

• Compare costs with known or assumed benefits of activities, identify value-added and

non-value-added activities, and make decisions to reduce resources devoted to

activities that are not cost-effective;

• Compare and determine reasons for variances between actual and budgeted costs of

an activity or a product;

• Compare cost changes over time and identify their causes;

• Identify and reduce excess capacity costs; and

• Compare costs of similar activities and find causes for cost differences, if any.

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Performance Measurement

34. Measuring performance is a means of improving program efficiency, effectiveness, and

program results. One of the stated purposes of the GPRA of 1993 is to “. . .improve the

confidence of the American people in the capability of the federal government, by

systematically holding federal agencies accountable for achieving program results.”

35. Measuring costs is an integral part of measuring performance in terms of efficiency and

cost-effectiveness. Efficiency is measured by relating outputs to inputs. It is often expressed

by the cost per unit of output. While effectiveness in itself is measured by the outcome or the

degree to which a predetermined objective is met, it is commonly combined with cost

information to show “cost-effectiveness.” Thus, the service efforts and accomplishments of a

government entity can be evaluated with the following measures:

(1) Measures of service efforts which include the costs of resources used to provide the

services and non-financial measures;

(2) Measures of accomplishments which are outputs (the quantity of services provided)

and outcomes (the results of those services); and

(3) Measures that relate efforts to accomplishments, Such as cost per unit of output or

cost-effectiveness.

36. Thus, as stated previously, performance measurement requires both financial and non-

financial measures. Cost is a necessary element for performance measurement, but is not

the only element.

Determining Reimbursements And Setting Fees And Prices

37. Cost information is an important basis in setting fees and reimbursements. Pricing and

costing, however, are two different concepts. Setting prices is a policy matter, sometimes

governed by statutory provisions and regulations, and other times by managerial or public

policies. Thus, the price of a good or service does not necessarily equal the cost of the good

or the service determined under a particular set of principles. Nevertheless, cost is an

important consideration in setting government prices. With certain exceptions, OMB

requires:

OMB Circular A-25, User Charges (Revised July 8, 1993).

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• With respect to goods and services that the government provides in its sovereign

capacity to a particular group of individuals as a special benefit, user charges should

be sufficient to recover the full cost of those goods and services; and

• With respect to goods and services that the government provides under business-like

conditions, user charges for those goods and services need not be limited to the

recovery of full cost and may yield a net revenue.

38. Also, cost information is important in calculating reimbursements for products and services

provided by one government agency to another. Even if fees or reimbursements do not

recover the full costs due to policy or economic constraints, management needs to be aware

of the difference between cost and price. With this information, program managers can

properly inform the public, the Congress, and federal executives about the costs of

providing the goods or services.

Program Evaluations

39. Costs of federal resources required by programs are an important factor in making policy

decisions related to program authorization, modification, and discontinuation. These

decisions are usually subject to policy constraints, and often require the consideration of

social and economic costs and benefits affecting different sectors of the economy and

society. Nevertheless, the costs of federal resources required are an important factor.

Information on program costs can be used as a basis for cost-benefit considerations.

Economic Choice Decisions

40. Often, agencies and programs face decisions involving choices among alternative actions,

such as whether to do a project in-house or contract it out; to accept or reject a proposal; or

to continue or drop a product or service. Making these decisions requires cost comparisons

among available alternatives.

Managerial Cost Accounting Concepts

Managerial cost accounting should be a fundamental part of the financial management system and, to the

extent practicable, should be integrated with other parts of the system. Managerial costing should use a

basis of accounting, recognition, and measurement appropriate for the intended purpose. Cost

information developed for different purposes should be drawn from a common data source, and output

reports should be reconcilable to each other.

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41. Managerial cost accounting should be an essential element of proper financial planning,

control, and evaluation for any organization or activity that uses resources having monetary

value. Managerial cost accounting is a basic part of the financial management system in

that it supports and provides data to the budgetary and financial accounting functions and,

by itself, provides useful information for both internal and external users.

Role Of Managerial Cost Accounting In Financial Management

42. Managerial cost accounting is the process of accumulating, measuring, analyzing,

interpreting, and reporting cost information useful to both internal and external groups

concerned with the way in which the organization uses, accounts for, safeguards, and

controls its resources to meet its objectives. Managerial cost accounting, therefore, is the

servant of both budgetary and financial accounting and reporting because it assists those

systems in providing information. Also, it provides useful information directly to

management. These relationships are shown in Figure 1.

Figure 1: Financial Management Information Framework

Common Data Source

43. The information flow within a financial management system begins with a basic information

pool or common data source. This data source consists of all financial and programmatic

information used by the budgetary, cost, and financial accounting processes. It includes all

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financial and much non-financial data, such as environmental data, that are necessary for

budgeting and financial reporting.

The common data source also includes evaluation and

decision information developed as a result of prior reporting and feedback. Other types of

data may be included based upon perceived needs and purposes related to the ultimate

users of the information.

44. The common data source may include many different kinds of data. It is far more than the

information about financial transactions found in the standard general ledger, although that

is a significant part of the data source. Few organizations or entities maintain all these data

in any one system or location. Furthermore, the use of the term “data source” is not meant

to imply the use of computerized systems for source information. Instead, the term is used

in a broad way to include many sources of information.

45. Managerial cost accounting, financial accounting, and budgetary accounting draw

information as needed from the common data source. The data obtained by each of these is

processed to attain specific objectives by reporting useful information.

Relationship to Financial Accounting

46. As shown in Figure 1 by their overlap, managerial cost accounting and financial accounting

are closely related or integrated. To some degree, this is due to the historical development

of cost accounting as a method for more detailed scorekeeping with the requirement to

provide inventory values for external financial reporting purposes.

In part, it is because

cost information generally originates with transactions recorded for financial accounting

purposes.

47. While inventory valuation is still part of the fundamental relationship, managerial cost

accounting serves financial accounting in several other ways. Fundamentally, managerial

cost accounting should assist financial accounting in determining the results of operations

during a fiscal period by providing relevant data that are accumulated to produce operating

expenses. These data include the allocation of capitalized costs to periods of time or units of

usage.

48. Traditionally, managerial cost accounting information pertaining to financial accounting has

involved costs of past transactions and the assignment of transaction value to fiscal periods

The makeup of core data and environmental data is discussed in Statement of Federal Financial Accounting

Concepts No. 1, Objectives of Federal Financial Reporting, Chapter 7, and, therefore, a detailed discussion is not

provided here.

Coulthurst, Nigel and John Piper, “The State of Cost and Management Accounting,” Management Accounting, April

1986.

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and outputs. These purposes and uses are closely aligned with the financial accounting

activity and traditional external financial reporting. This past cost aspect has been

acknowledged in Objectives of Federal Financial Reporting which states that “financial

accounting is largely concerned with assigning the value of past transactions to appropriate

time periods.”

Relationship to Budgetary Accounting

49. Managerial cost accounting should also provide budgetary accounting with cost information.

However, the two are not as closely aligned as is the case with financial accounting (see

Figure 1). Mostly, this is because costs are usually recorded, accumulated, and allocated by

managerial cost accounting on an accrual basis of accounting which is different from the

obligation or cash basis generally used in budgetary accounting.

50. Still, managerial cost accounting does provide cost information to budgetary accounting for

use in preparing yearly and long-term budgets for required materials, supplies, equipment,

human resources, and other resources needed to produce different levels of outputs.

Managerial cost accounting also helps in making many budgetary decisions such as those

concerning future capital expenditures and purchase/lease alternatives.

51. It is important to note that the Board’s authority does not extend to recommending

budgetary standards or budgetary concepts, and that is not the purpose of this statement.

However, the Board is committed to providing relevant and reliable cost accounting

information that supports budget planning, formulation, and execution.

Cost Information for Management Purposes

52. Managerial cost accounting produces information directly for management use, sometimes

employing data produced by the budgetary and financial accounting processes. Cost

information is used for many different purposes which can be generally classified into five

types: performance measurement; cost reduction and control; determination of

reimbursements and fee or price setting; program authorization, modification, and

discontinuation decisions; and decisions to contract out work or make other changes in the

methods of production.

53. To meet these needs, managerial cost accounting should use basic cost data and non-

financial or programmatic data. For example, it tracks units of output produced and input

Statement of Federal Financial Accounting Concepts No. 1, Objectives of Federal Financial Reporting, par. 168.

Memorandum of Understanding establishing the FASAB, October 10, 1990.

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used including the amount of labor in terms of employees or employee-hours. Sometimes,

information from cost analysis is used to compare actual to predetermined or anticipated

costs. An organization may use cost estimates, cost studies, and cost finding techniques.

54. While managerial cost accounting is concerned not only with past costs and future costs,

one of its most important features is the use of present costs to assist management. This

current cost aspect of managerial cost accounting is referred to in the Objectives of Federal

Financial Reporting where is states that “accounting data may be further assigned,

allocated, or associated with units of activity or production, segments of organizations, etc.,

within the same time period. These kinds of intraperiod allocations are developed most

extensively in the branch of accounting called cost accounting. Neither the FASB nor the

GASB has devoted much attention to this branch of accounting, but the FASAB, because of

its unique mission, will need to do so.”

Managerial cost accounting information pertaining

to present costs is most often used for controlling and reducing those costs, controlling work

processes, and measuring current performance.

Reporting Relationships

55. Proper financial management requires that the three accounting processes work closely

together to provide useful reporting to both internal and external users. The internal-external

dual focus of federal reporting has been established in the Objectives of Federal Financial

Reporting. It states that “The FASAB and its sponsors believe that any description of federal

financial reporting objectives should consider the needs of both internal and external users

and the decisions they make.” In addition, it says that “the FASAB... considers the

information needs of both internal and external users. In part, this is because the distinction

between internal and external users is in many ways less significant for the federal

government than for other entities.” It goes on to classify the users of financial information

into four major groups: program managers, executives, the Congress, and citizens.

These

categories include both internal and external users.

56. Federal financial reporting encompasses general and special purpose reports to meet the

needs of the four user groups. Information produced by managerial cost accounting appears

in or influences both types of reports.

As discussed above, managerial cost accounting

should provide information for use by both financial accounting and budgetary accounting.

Statement of Federal Financial Accounting Concepts No. 1, Objectives of Federal Financial Reporting, par. 174.

Ibid., pars. 23, 25, and par. 75.

The types of general purpose and special purpose reports are discussed in Statement of Federal Financial

Accounting Concepts No. 1, Objectives of Federal Financial Reporting, Chapter 7.

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That information is used by those processes in producing both general purpose and special

purpose reports.

57. Managerial cost accounting also results in reports of its own. Most often these are special

purpose reports designed for internal users, typically program and line managers. However,

they may be for groups generally considered external users.

58. One of the most important aspects of reporting in which managerial cost accounting plays a

large role is that of performance reporting. Measuring and reporting actual performance

against established goals is essential to assess governmental accountability. Cost

information is necessary in establishing strategic goals, measuring service efforts and

accomplishments, and relating efforts to accomplishments. The importance of cost

information in relation to performance measurement and performance reporting has been

recognized in the Objectives of Federal Financial Reporting, which said “One reason for

performing cost accounting is to assist in performance measurement” and it also stated that

“The topics of cost and performance measurement are related because it is by associating

cost with activities or ‘cost objectives’ that accounting can make much of its contribution to

reporting on performance.”

Basis Of Accounting And Recognition/measurement Methods

59. Costs may be measured, analyzed, and reported in many ways. A particular cost

measurement has meaning only when considering its purpose. The measurement of costs

can vary depending upon the circumstances and purpose for which the measurement is to

be used. In Objectives of Federal Financial Reporting, it is stated that “the Board’s own

focus is on developing generally accepted accounting standards for reporting on the

financial operations, financial position, and financial condition of the federal government and

its component entities and other useful financial information. This implies a variety of

measures of costs and other information that complements the information available in the

budget [emphasis added].”

60. In addition, it is stated that “In defining the proper measurement, assignment, and allocation

of cost for a given purpose, selecting the appropriate accounting method and whether to use

full costing should be carefully considered.”

Further, it added that “The accrual basis of

Ibid., par. 174 and par. 192.

Ibid., par. 191.

Ibid., par. 196.

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accounting generally provides a better matching of costs to the production of goods and

services, but its use and application for any given purpose must be carefully evaluated.”

61. Therefore, managerial cost accounting should provide cost information using a basis of

accounting and recognition/measurement standards that are appropriate for the intended

use of the information. When managerial cost accounting is used to supply information for

use by financial accounting and financial reporting, that information should be consistent

with the basis of accounting and recognition/measurement standards required by federal

accounting principles. Traditionally this has meant the use of accrual accounting and

historical cost measurement, particularly in general purpose reports.

62. When managerial cost accounting is used to supply information for the preparation and

review of budgets, cost data should be consistent with the basis of accounting and

recognition/measurement used in financial reporting, but may be adjusted to meet the

budgetary information needs.

63. Special purpose cost studies and analyses are sometimes performed for decision making.

In those studies and analyses, management may need to develop cost data beyond those

currently reported in general purpose financial reports. For example, in making planning

decisions, management may develop replacement costs and capital costs. However, the

basis and methods used should be appropriate for the circumstances and consistent with

the intended purposes.

Reconciliation Of Information

64. Different bases of accounting will produce different costs for the same item, activity, or

entity. This can confuse users of cost information. Therefore, reports that use different

accounting bases or different recognition and measurement methods should be

reconcilable, and should fully explain those bases and methods. Regardless of the type of

report in which it is presented, cost information should ultimately be traceable back to the

original common data source.

65. To be reconcilable, the amount of the differences in the information reported should be

ascertainable and the reasons for the differences should be explainable. In some situations,

informational differences may be clearly understandable without further explanation.

However, other cases may require a narrative statement concerning the differences. In

complicated situations, a schedule or table may be required to fully explain the differences.

Ibid., par. 197.

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66. Financial reporting has long recognized the necessity for reconciliation between information

reported on different accounting bases. Reconciliations have been required in federal

financial reports to show and explain significant differences between budget reports and

financial statements prepared in accordance with generally accepted accounting principles.

Managerial Cost Accounting Standards

Requirement For Cost Accounting

67. Cost information is essential to effective financial management and should play an

important role in federal financial reporting. Managerial cost accounting processes are the

means of providing cost information in an efficient and reliable manner on a continuing

basis.

Need For Consistent Cost Accounting On A Regular Basis

68. To perform managerial cost accounting on a “regular basis” means that entities should

establish procedures to accumulate and report costs continuously, routinely, and

consistently for management information purposes. Consistent and regular cost accounting

is needed to meet the second objective of federal financial reporting which states

information should be provided to help the user determine the costs of providing specific

programs and activities and the composition of, and changes in those costs. That objective

also requires the reporting of performance information of federal programs and the changes

over time in that performance in relation to the costs.

69. The requirement for managerial cost accounting on a regular and consistent basis supports

recent legislative actions. The CFO Act of 1990 states that agency CFOs shall provide for

the development and reporting of cost information and the periodic measurement of

performance. In addition, the GPRA of 1993 requires each agency, for each program, to

establish performance indicators and measure or assess relevant outputs, service levels,

and outcomes of each program as a basis for comparing actual results with established

Each reporting entity

should accumulate and report the cost of its activities on a regular basis for

management information purposes. Costs may be accumulated either through the use of cost accounting

systems or through the use of cost finding techniques.

The term “reporting entity” as used in this document conveys the same meaning as defined in FASAB Statement of

Recommended Accounting Concepts No. 2, Entity and Display (May 1995).

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goals. The nature of these legislative mandates requires reporting entities to develop and

report cost information on a consistent and regular basis.

70. The managerial cost accounting processes consist of collecting data from the common data

source, processing that data, and reporting cost and output information in general purpose

and special purpose reports. Appropriate procedures and practices should also be

established to enable the collection, measurement, accumulation, analysis, interpretation,

and communication of cost information. This can be accomplished through the use of a cost

accounting system or the use of cost finding techniques and other cost studies and

analyses. A cost accounting “system” is an organized grouping of methods and activities

designed to consistently produce reliable cost information.

Basic Cost Accounting Processes

71. Regardless of whether a reporting entity uses a cost accounting system or cost finding

techniques, the methods and procedures followed should be designed to perform at least a

certain minimum level of cost accounting and provide a basic amount of cost information

necessary to accomplish the many objectives associated with planning, decision making,

control, and reporting. The more important of these minimum criteria for cost accounting are

associated with the standards in the remainder of this statement. Others are also important.

• Responsibility Segments - Cost information should be collected by responsibility

segments which have been identified by management and outputs should be defined

for each responsibility segment.

• Full Costing - Each reporting entity should measure the full cost of outputs so that total

operational costs and total unit costs of outputs can be determined. “Full cost” includes

the cost of goods or services provided by other entities when the applicable criteria are

met.

• Costing Methodology - The costing methodology used (e.g., activity-based costing, job

order costing, standard costing, etc.) should be appropriate for management’s needs

and the operating environment.

• Performance Measurement - Cost accounting should provide information needed to

determine and report service efforts and accomplishments and information necessary

to meet the requirements of the GPRA or interface with a system that provides such

See standard in this statement concerning responsibility segments.

See standard concerning full costs and standard concerning inter-entity costing.

See standard concerning costing methodology.

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information. This includes the quantity of inputs and outputs and other non-financial

information needed in the measurement of performance.

• Reporting Frequency - Cost information should be reported in a timely manner and on

a regular basis consistent with the needs of management and the requirements of both

budgetary and financial reporting.

• Standard General Ledger - Managerial cost accounting should be integrated with

general financial accounting. Both depend on the standard general ledger for basic

financial transaction data.

• Precision of Information - Cost information supplied to internal and external users

should be reliable and useful in making evaluations or decisions. At the same time,

unnecessary precision and refinement of data should be avoided.

• Special Situations - The managerial cost accounting processes should be designed to

accommodate any of management’s special cost information needs that may arise due

to unusual or special situations or circumstances. If such cost information is needed on

a regular basis, appropriate procedures to provide it should be developed.

• Documentation - All managerial cost accounting activities, processes, and procedures

should be documented by a manual, handbook, or guidebook of applicable accounting

operations. This reference should outline the applicable activities, provide instructions

for procedures and practices to be followed, list the cost accounts and subsidiary

accounts related to the standard general ledger, and contain examples of forms and

other documents used.

Complexity Of Cost Accounting Processes

72. While each entity’s managerial cost accounting should meet the basics discussed above,

this standard does not specify the degree of complexity or sophistication of any managerial

cost accounting process. Each reporting entity should determine the appropriate detail for

its cost accounting processes and procedures based on several factors. These include the:

• nature of the entity’s operations;

• precision desired and needed in cost information;

• practicality of data collection and processing;

• availability of electronic data handling facilities;

• cost of installing, operating, and maintaining the cost accounting processes; and

• any specific information needs of management.

73. Some entities may find that they can purchase basic “off-the-shelf” cost accounting

programs, systems, or processes, or adapt those of other federal agencies. All entities

should consider using similar or compatible cost accounting processes throughout their

component units to facilitate comparison and consolidation of cost information.

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Cost Findings, Studies, And Analyses

74. A cost accounting system is a continuous and systematic cost accounting process which

may be designed to accumulate and assign costs to a variety of objects routinely or as

desired by the management. Such a system may be best for some reporting entities.

75. Some entities may not need a sophisticated system to perform detailed cost accumulation

and assignment. They need to accumulate and report costs regularly as required by this

standard, but they may determine and analyze costs through special cost studies and

analyses. Also, some entities may use a combination of a system supplemented by cost

studies.

76. Cost information may be developed and savings achieved in some cases by the use of

special cost studies or cost analyses to develop information helpful in certain decision

making situations. In addition, cost finding techniques may be used to determine the cost of

products or services. Cost finding is a method for determining the cost of producing goods

or services using appropriate procedures. Cost finding techniques may also be useful for

computing costs in cases where the information is not needed on a recurring basis.

Responsibility Segments

77. The standard states that the management of each reporting entity should define and

establish responsibility segments. This section explains the concept of responsibility

segment, purposes of segmentation, and how responsibility segments can be structured.

Defining Responsibility Segments

78. A responsibility segment is a component of a reporting entity

that is responsible for

carrying out a mission, conducting a major line of activity, or producing one or a group of

related products or services. In addition, responsibility segments usually possess the

following characteristics:

(1) Their managers report to the entity’s top management directly;

Management of each reporting entity should define and establish responsibility segments. Managerial cost

accounting should be performed to measure and report the costs of each segment’s outputs. Special cost

studies, if necessary, should also be performed to determine the costs of outputs.

The term “reporting entity” referred to in this document conveys the same meaning as defined in FASAB Statement of

Recommended Accounting Concepts No. 2, Entity and Display (May 1995).

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(2) Their resources and results of operations can be clearly distinguished from those of

other segments of the entity.

79. A responsibility segment is a unit for which managerial cost accounting is performed.

Entities may use a centralized accounting system or segment-based systems to provide

cost information for each segment. For each segment, managerial cost accounting should:

(1) Define and accumulate outputs, and if feasible, quantify each type of output in units;

(2) Accumulate costs and quantitative units of resources consumed in producing the

outputs; and

(3) Assign costs to outputs, and calculate the cost per unit of each type of output.

80. Some reporting entities may have only one responsibility segment, if they perform one

single mission or one type of service. Other reporting entities may have several

responsibility segments. Also, a sub-organization of the federal government may be a

reporting entity in itself and, at the same time, it may also be a responsibility segment of a

higher level reporting entity to which it belongs. The Forest Service, for example, may be a

reporting entity because it may meet the reporting entity criteria. As such, it may establish

responsibility segments for itself. At the same time, the Forest Service may be regarded as

a responsibility segment of the Department of Agriculture, of which it is a component.

81. However, for a given reporting entity, its management should establish one or more

responsibility segments to perform managerial cost accounting functions.

Purposes Of Segmentation

82. A basic purpose of dividing an entity into segments is to determine and report the costs of

services and products that each segment produces and delivers. Many federal departments

and agencies manage programs that produce a variety of goods and services. Accounting

for entity-wide revenues and expenses in aggregate would serve financial reporting for the

entity, but would not serve costing purposes. In order to determine the cost of each type of

service or product, it is necessary to divide an entity into segments such that each segment

is responsible for certain types of services or products. Each segment can then be used as

a vehicle for accumulating costs incurred by the segment to match with its outputs. Each

segment can use a cost methodology that is best suited to its operations.

These two characteristics make responsibility segments, as the term is used in this document, differ from cost

centers. A cost center can be at any level of an organization and may not report to the top management directly. As will

be explained later, a responsibility segment can contain cost centers in itself.

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83. Another important purpose of segmentation is to facilitate cost control and management.

Cost information provided for each segment helps managers to examine costs of specific

resources consumed and activities performed in each segment. Managers can analyze cost

variances in both dollars and the units of resources consumed against budgets or

standards. Since each segment performs a particular pattern of processes and activities to

produce its output, managers can analyze those processes and activities to compare their

costs with the value they contribute to the output.

84. For entities that consist of components engaging in diverse lines of activities, it is desirable

to provide financial reports that display information for significant components individually

and of the entity in its entirety.

Some entities may find costs accumulated by segments

useful in support of financial reporting by components.

85. For internal management, segmentation could also facilitate performance measurement.

Since each segment is responsible for a mission, or a line of activity to produce a certain

type of output, performance goals can be set for each segment based on its specific tasks

and operating patterns. Information on costs, outputs, and outcomes related to each

segment can be used to measure its performance against the goals. The results of the

segment performance measurement could also support external reporting on performance

measures for the entire reporting entity or its major programs.

Structuring Responsibility Segments

86. Reporting entity management should define and structure its responsibility segments. The

designation of responsibility segments should be based on the following factors: (a) the

entity’s organization structure, (b) its lines of responsibilities and missions, (c) its outputs

(goods or services it delivers), and (d) budget accounts and funding authorities. However,

the predominant factor is the reporting entity’s organization structure and its existing

responsibility components, such as bureaus, administrations, offices, and divisions within a

department.

87. The U.S. General Services Administration, for example, provides five distinct services: (1)

managing public buildings, (2) distributing supplies, (3) providing travel and transportation

services, (4) managing information resources (including communication and data

processing services), and (5) disposal of real properties. Each of those service areas could

be designated as a responsibility segment. The Department of Veterans Affairs (VA), among

its other services, provides health care to veterans, pays veterans’ compensation and

This point is discussed in FASAB Statement of Recommended Accounting Concepts No. 2, Entity and Display, pars.

75-76.

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pension benefits, and provides home loans and home loan guarantees to veterans. Each of

these program areas could constitute a responsibility segment.

88. Since responsibility segments are major parts of an entity, some segments may carry more

than one program. Some programs may be jointly managed by two or more segments.

Thus, each segment must accumulate costs for each type of output produced for various

programs. To accomplish this, a network of cost centers can be established within a

segment to accumulate costs. Managers of each cost center will be provided with

information to control and manage costs within their area of responsibility. Depending on

operational patterns and cost methods, cost centers can be structured along different

dimensions, such as organizational units, operating processes, and activities.

Full Cost

89. This standard states that reporting entities should measure and report the full costs of their

outputs in general purpose financial reports. “Outputs” means products and services

generated from the consumption of resources. The full cost of a responsibility segment’s

output is the total amount of resources used to produce the output. This includes direct and

indirect costs that contribute to the output, regardless of funding sources. It also includes

costs of supporting services provided by other responsibility segments or entities. The

standard does not require full cost reporting in federal entities’ internal reports or special

purpose cost studies. Entity management can decide on a case-by-case basis whether full

cost is appropriate and should be used for internal reporting and special purpose cost

studies.

Direct Costs

90. Direct costs are costs that can be specifically identified with an output. All direct costs

should be included in the full cost of outputs. Typical direct costs in the production of an

output include:

(a) Salaries and other benefits for employees who work directly on the output;

(b) Materials and supplies used in the work;

Reporting entities should report the full costs of outputs in general purpose financial reports. The full cost

of an output produced by a responsibility segment is the sum of (1) the costs of resources consumed by

the segment that directly or indirectly contribute to the output, and (2) the costs of identifiable supporting

services provided by other responsibility segments within the reporting entity, and by other reporting

entities.

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used exclusively to produce the output; and

(d) Costs of goods or services received from other segments or entities that are used to

produce the output (See discussions and explanations in the next section on “Inter-

Entity Costs”).

Indirect Costs

91. Indirect costs are costs of resources that are jointly or commonly used to produce two or

more types of outputs but are not specifically identifiable with any of the outputs. Typical

examples of indirect costs include costs of general administrative services, general research

and technical support, security, rent, employee health and recreation facilities, and

operating and maintenance costs for buildings, equipment, and utilities. There are two levels

of indirect costs:

(a) Indirect costs incurred within a responsibility segment. These indirect costs should be

assigned to outputs on a cause-and-effect basis, if such an assignment is economically

feasible, or through reasonable allocations. (See discussions on cost assignments in

the “Costing Methodology” section.)

(b) Costs of support services that a responsibility segment receives from other segments

or entities. The support costs should be first directly traced or assigned to various

segments that receive the support services. They should then be assigned to outputs.

92. A reporting entity and its responsibility segments may incur general management and

administrative support costs that cannot be traced, assigned, or allocated to segments and

their outputs. These unassigned costs are part of the organization costs, and they should be

reported on the entity’s financial statements (such as the Statement of Net Costs) as costs

not assigned to programs.

Certain Cost Elements

Costs of Employees’ Benefits

93. Employee benefits include:

A similar explanation is provided in FASAB Statement of Recommended Accounting Concepts No. 2, Entity and

Display, par. 95.

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(a) Health and life insurance benefits for current employees covered in part by the

government’s contribution to health and life insurance premiums;

(b) Pension benefits for employees, their survivors, and dependents, covered by defined

pension plans such as Civil Service Retirement System (CSRS), Federal Employees

Retirement Plan (FERS), and Military Retirement System (MRS);

dependents, covered in part by the government’s contribution to health and life

insurance premiums, and referred to as “other retirement benefits” (ORB) in this

document;

(d) Other postemployment benefits (OPEB) for terminated and inactive employees, which

include severance payments, training and counseling, continued health care, and

unemployment and workers compensation.

94. Most of the employee benefit programs are covered by trust funds administered by the

Office of Personnel Management (OPM) and the Department of Defense (DoD).

Contributions to the trust funds come from three sources: current and retired employees,

employing agencies, and direct appropriations. The management expenses of the trust

funds are paid with the funds’ receipts.

95. Federal financial accounting standards require that the employing entity accrue the costs to

the federal government of providing pension and ORB benefits to employees and recognize

the costs as an expense when the benefits are earned.

The employing entity should

recognize those expenses regardless of whether the benefits are funded by the reporting

entity or by direct appropriations to the trust funds. This principle should also be applied to

health and life insurance benefits for current employees and comparable benefits for military

personnel. The costs of employee benefits incurred by responsibility segments should be

directly traced or assigned to outputs.

96. OPEB costs include severance payments, counseling and training, health care, and workers

compensation benefits paid to former or inactive employees. OPEB costs are often incurred

as a result of such events as reductions in force or on-the-job injuries of employees. Federal

financial accounting standards require that OPEB costs be reported as an expense for the

period during which a future outflow or other sacrifice of resources is probable and

measurable on the basis of events occurring on or before the accounting date.

FASAB Exposure Draft, Accounting for Liabilities of the Federal Government

(November 7, 1994), pars. 62-99.

Ibid., pars. 100-102.

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97. Since the recognition of OPEB costs is linked to the occurrence of an OPEB event rather

then the production of output, in many instances, assigning OPEB costs recognized for a

period to output of that period would distort the cost of output. In special purpose cost

studies or cost findings, management may distribute OPEB costs over a number of years in

the past to determine the costs of the outputs that the OPEB recipients helped to produce.

Costs of Public Assistance and Social Insurance Programs

98. Major costs of welfare, insurance, and grant programs are the costs of resources transferred

from the federal government to individuals and state and local governments. Some of them

are referred to as “transfer payments.” The following are some typical public assistance and

insurance programs:

• Grants, such as aid to state and local governments;

• Subsidies, such as agricultural commodity price support and stabilization programs;

• Credit and insurance costs, such as the Family Education Loan Program and Savings

Association Insurance;

• Welfare payments such as Aid to Families with Dependent Children (AFDC); and,

• Social insurance, such as the Old Age, Survivors, and Disability Insurance Program.

99. The full cost of such a program includes: (a) the costs of federal resources that have been

or will be transferred to individuals and state/local governments, and (b) the costs of

operating the programs. These two types of costs should be recognized on a basis of

accounting that is prescribed within the Federal Financial Accounting Standards. These two

types of costs should be separately identified so that each can be used for different analytic

purposes.

100. The costs resulting from transfer payments are determined by the level of grants, subsidies,

entitlement benefits, credit subsidies, or loss payments made under insurance and

guarantee agreements. They are also determined by the number of eligible persons who

receive the transfer payments. The program cost of AFDC, for example, depends on the

average payment per family, the number of eligible families, and the federal government’s

share in the payments (some payments are made by state and local governments).

Information on this type of cost is useful for making policy decisions about levels of

subsidies or benefits, eligibility of recipients, and how transfer payments are made. This cost

information is also useful for measuring the cost-effectiveness of a transfer payment

program.

101. Program operating costs, on the other hand, are costs of managing the program and

delivering the payments. They include the costs of personnel, supplies, equipment, and

offices. The costs are related to such activities as screening benefit recipients for eligibility,

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keeping their accounts, making payments and collections, answering inquiries, etc.

Information on this type of cost is useful in measuring the efficiency of program operations.

Costs related to Property, Plant and Equipment

102. Depreciation expense. General property, plant, and equipment are used in the production

of goods and services. Their consumption is recognized as depreciation expense. The

depreciation expense incurred by responsibility segments should be included in the full

costs of the goods and services that the segments produce.

103. Recognizing property acquisition costs as expenses. The costs of acquiring or

constructing federal mission and heritage property, plant, and equipment may be charged to

expenses at the time the acquisition costs are incurred.

Since the recognition of these

expenses is linked to property acquisition rather than production of goods and services,

those expenses should not be included in the full costs of goods and services. However,

they are part of the costs of the entity or the program that makes the property acquisitions.

Non-production costs

104. A responsibility segment may incur and recognize costs that are linked to events other than

the production of goods and services. Two examples of these non-production costs were

discussed earlier: (1) OPEB costs that are recognized as expenses when an OPEB event

occurs, and (2) certain property acquisition costs that are recognized as expenses at the

time of acquisition. Other non-production costs include reorganization costs, and

nonrecurring cleanup costs resulting from facility abandonments that are not accrued. Since

these costs are recognized for a period in which a particular event occurs, assigning these

costs to goods and service produced in that period would distort the production costs. In

special purpose cost studies, management may have reasons to determine historical output

costs by distributing some of these costs to outputs over a number of past periods. Such

distribution may be appropriate when: (a) experience shows that the costs are recurring in a

regular pattern, and

(b) a nexus can be established between the costs and the production of

outputs that may have benefited from those costs.

In FASAB Exposure Draft, Accounting for Property, Plant, and Equipment, the Board proposed that the costs of

acquiring or constructing “federal mission” and “heritage” property, plant, and equipment be recognized as expenses

when the costs are incurred. See the ED, pars. 98-117, pages 29-34.

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Inter-entity Costs

105. As stated in the preceding standard, to fully account for the costs of the goods and services

they produce, reporting entities should include the cost of goods and services received from

other entities. Knowledge of these costs is helpful to top level management in controlling

and assessing the operating environment. It is also helpful to other users in evaluating

overall program costs and performance and in making decisions about resource allocations

and changes in programs.

Inter-entity Activities

106. Within the federal government, some reporting entities rely on other federal entities to help

them achieve their missions. Often this involves support services, but may include the

provision of goods. Sometimes these arrangements may be stipulated by law, but others are

established by mutual agreement of the entities involved. Such relationships can be

classified into two types depending upon funding methods.

• Provision of goods or services with reimbursement

—In this situation, one entity agrees

to provide goods or services to another with reimbursement at an agreed-upon price.

The reimbursement price may or may not be enough to recover full costs. Usually the

agreement is voluntarily established through an inter-agency agreement. Revolving

funds can also be included in this group, because they are usually established to

recover costs through sale of their outputs to other government entities. They are

usually meant to be self-sustaining through their sales, without receiving additional

appropriations. However, they do not always charge enough to cover full costs.

• Provision of goods or services without reimbursement

—One entity provides goods or

services to another entity free of charge. The agreement may be voluntary, legally

mandated, or inherently established in the mission of the providing entity.

107. Recently, consideration has been given to expanding the concept of inter-entity support

within the federal government. Under this concept, entities could sell their outputs on a

competitive basis. Entities would have the authority to purchase goods or services from any

federal or private provider. This is seen as a way to improve government efficiency through

Each entity’s full cost should incorporate the full cost of goods and services that it receives from other

entities. The entity providing the goods or services has the responsibility to provide the receiving entity

with information on the full cost of such goods or services either through billing or other advice.

Recognition of inter-entity costs that are not fully reimbursed is limited to material items that (1) are

significant to the receiving entity, (2) form an integral or necessary part of the receiving entity’s output, and

(3) can be identified or matched to the receiving entity with reasonable precision. Broad and general

support services provided by an entity to all or most other entities should not be recognized unless such

services form a vital and integral part of the operations or output of the receiving entity.

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competition since inefficient government providers would be forced to improve or stop

providing these goods or services. This could result in consolidating support services in

fewer governmental entities. Underlying this concept is the requirement that all costs be

recognized in developing the price at which goods and services would be sold to other

entities.

Accounting And Implementation Guidance

31A

108. If an entity provides goods or services to another entity, regardless of whether full

reimbursement is received, the providing entity should continue to recognize in its

accounting records the full cost of those goods or services. The full costs of the goods or

services provided should also be reported to the receiving entity by the providing entity.

109. The receiving entity should recognize in its accounting records the full cost of the goods or

services it receives as an expense or, if appropriate, as an asset (such as work-in-process

inventory). The information on costs of non-reimbursed or under-reimbursed goods or

services should be available from the providing entity. However, if such cost information is

not provided, or is partially provided, a reasonable estimate may be used by the receiving

entity. The estimate should be of the cost of the goods or services received (the estimate

may be based on the market value of the goods or services received if an estimate of the

cost cannot be made). To the extent that reimbursement is less than full cost, the receiving

entity should recognize the difference in its accounting records as a financing source.

Inter-entity expenses/assets and financing sources would be eliminated for any

consolidated financial statements covering both entities.

Recognition

110. Implementation of this standard on inter-entity costing should be accomplished in a practical

and consistent manner by federal entities. The Office of Management and Budget may

31A

These paragraphs should be read in conjunction with “Recognition” paragraphs 110 -113 to provide a complete

understanding of the implementation of standard on inter-entity costing due to different recognition requirements for

certain types of activities.

See Statement of Recommended Federal Accounting Concepts No. 2, Entity and Display, par. 65. See also, FASAB

Exposure Draft, Accounting for Liabilities of the Federal Government, pars. 62-99, pages 26-46, which addresses

accounting for pensions and other retirement benefits (ORB). The payment of pension and ORB costs for an entity by

another entity has often been likened to providing goods and services. In the case of pensions, employees of the

reporting entity provide services to that entity and part of the salary-related cost is paid by a different entity. The

pension administering entity does not provide goods or services to the reporting entity (other than normal pension

administration services), but rather pays their costs directly. The difference is subtle but important. However, the

accounting is similar. This document is consistent with the section of the liabilities exposure draft dealing with

accounting for pensions and other retirement benefits.

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issue guidance identifying additional inter-entity costs entities should recognize. The inter-

entity costs should be specified in accordance with this standard including the recognition

criteria presented in paragraphs 111 through 113.

111. Recognition of all significant inter-entity costs is important when those costs constitute

inputs to government goods or services provided for a fee or user charge. Generally, the

fees and user charges should recover the full costs of those goods and services.

Thus, the

cost of inter-entity goods or services needs to be recognized by the receiving entity in order

to determine fees or user charges for goods and services sold by the federal government.

Recognition of inter-entity costs supporting business-type activities

33A

and recognition of

inter-entity costs for non-business type activities that elect to do so should be made in

accordance with implementation guidance provided by FASAB through one or more

Technical Releases.

33B

Activities that are not business-type activities are not required to

recognize inter-entity costs other than inter-entity costs for personnel benefits and the

Treasury Judgment Fund settlements unless otherwise directed by OMB. Notwithstanding

the absence of a requirement, non-business-type activities may elect to recognize imputed

cost and corresponding imputed financing for other types of inter-entity costs.

112. However, the situation is often different with goods or services transferred within the federal

government that do not involve eventual sales to entities outside the federal government.

The federal government in its entirety is an economic entity. Therefore, it is reasonable to

expect some flow of goods or services between reporting entities as those entities assist

each other in fulfilling their missions and operating objectives. There are some cases in

which the cost of non-reimbursed or under-reimbursed goods or services received from

other entities need not be recognized as part of the cost of the receiving entity. The following

general criteria are provided to help in determining the types of inter-entity costs that should

or should not be recognized.

• Materiality

—As with other accounting standards, the provisions of this standard need

not be applied to immaterial items. However, in the context of deciding which inter-

entity transactions are to be recognized, materiality, as used here, is directed to the

individual inter-entity transaction rather than to all inter-entity transactions as a whole.

Under this concept, a much more limited recognition is intended than would be

OMB Circular A-25 addresses user charges by federal entities.

33A

Business-type activity is defined as a significantly self-sustaining activity which finances its continuing

cycle of operations through collection of exchange revenue as defined in SFFAS 7, Accounting for Revenue

and Other Financing Sources and Concepts for Reconciling Budgetary and Financial Accounting. (See also

SFFAS 6, Accounting for Property, Plant, and Equipment, footnote 27.)

33B

Technical Release (TR) 8, Clarification of Standards Relating to Inter-Entity Costs provides

implementation guidance. Additional TRs may be provided by FASAB if needed.

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achieved by reference to the general materiality concept.

In this context, then, materiality should be considered in terms of the importance of the

inter-entity transaction to the receiving entity. The importance of the transactions, and

thereby their recognition, should be judged in light of the following factors:

 Significance to the entity—The cost of the good or service is large enough that

management should be aware of the cost when making decisions.

 Directness of relationship to the entity’s operations—The good or service provided

is an integral part of and necessary to the output produced by the entity.

 Identifiability—The cost of the good or service provided to the entity can be

matched to the entity with reasonable precision.

The determination of whether the cost is material requires the exercise of

considerable judgment, based on the specific facts and circumstances of each

transaction.

• Broad, general support

—Some entities provide broad, general support to many, if not

all, reporting entities in the federal government. Most often this type of support involves

the establishment of policies and/or the provision of general guidance. The costs of

such broad services should not be recognized as an expense (or asset) by the

receiving entities when there is no reimbursement of costs. Thus the standard does not

apply when support is of a general nature provided to all or most entities of the federal

government.

An example of this situation can be found in the Office of Management and Budget

which establishes policy and provides general guidance to all parts of the executive

branch of government. The costs of OMB should not be spread over all reporting

entities because the services provided are (1) general and broad in scope, (2) provided

to almost all reporting entities in the executive branch, and (3) not specifically or

directly tied to the receiving entity’s outputs.

On the other hand, some services provided, under certain circumstances, should still

be recognized even though they may be considered broad and general in nature if

such services are integral to the operations of the receiving entity. Such services

include check writing by the Department of Treasury or legal activities performed by the

Department of Justice. For example, when the issuance of checks is integral to the

operations of an entity (e.g., the Internal Revenue Service and the Social Security

Administration), the receiving entity should include the full cost of issuing checks in the

full cost of its outputs. However, if the issuance of checks is insignificant and incidental

to the operations of an entity, the entity should not normally recognize that cost.

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113. The decision as to whether the cost of non-reimbursed or under-reimbursed goods and

services should be recognized requires the use of judgement. None of the criteria listed

above are, by themselves, fully or exclusively determinative. They should be considered

in combination. Ultimately, inclusion or exclusion of the cost should be decided based on

the specific facts and circumstances of each case, with consideration of the degree to

which inclusion or exclusion would change or influence the actions and decisions of a

reasonable person relying on the information provided.

Component Reporting Entity Disclosures

113A. Component reporting entities should disclose that only certain inter-entity costs are

recognized for goods and services that are received from other federal entities at no cost

or at a cost less than the full cost. An example disclosure includes:

Goods and services are received from other federal entities at no cost or at a cost less

than the full cost to the providing federal entity. Consistent with accounting standards,

certain costs of the providing entity that are not fully reimbursed [by the component

reporting entity] are recognized as imputed cost [in the Statement of Net Cost], and are

offset by imputed revenue [in the Statement of Changes in Net Position]. Such imputed

costs and revenues relate to business-type activities (if applicable), employee benefits,

and claims to be settled by the Treasury Judgment Fund.

33C

However, unreimbursed

costs of goods and services other than those identified above are not included in our

financial statements.

Accounting Example

114. The following tables provide an example of the accounting entries to be made when the

receiving entity (Agency R) recognizes an expense for services received from a providing

entity (Agency P) on a non-reimbursable basis. In the example, the full costs of these

services to Agency P are $100,000.

115. Agency R recognizes an “Expense of services provided by Agency P” equal to the full cost

of the services received. It also recognizes a financing source, “Services provided by

Agency P,” equal to the amount not reimbursed, which in this case is the full $100,000.

Agency P recognizes an “Expense of services provided to Agency R” equal to the full cost

of the services provided with a credit to “Appropriations used.”

33C

For simplicity, the illustration addresses only the unreimbursed costs required to be imputed by accounting

standards. Component reporting entities should identify the general nature of other imputed costs recognized in their

financial statements.

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Table 1: Agency R’s Accounting Entries*

Note: This example shows the cost recognized as an expense. However, as discussed in the text, it may be an asset.

Table 2: Agency P’s Accounting Entries

Costing Methodology

116. This standard addresses two aspects of costing: cost accumulation and cost assignment.

Each of them is explained and discussed below.

Cost Accumulation

117. Cost accumulation is the process of collecting cost data in an organized way. The standard

requires that costs be accumulated by responsibility segments. The accumulation is for

costs incurred within each responsibility segment, and does not involve the assignment or

allocation of costs incurred by other supporting segments, which will be discussed in the

latter part of this section.

Debit Credit

Expense of services provided by Agency P $100,000

Services provided by Agency P $100,000

Debit Credit

Expense of services provided to Agency R $100,000

Appropriated capital $100,000

Fund balance with Treasury $100,000

Appropriated capital used $100,000

Costs of resources consumed by responsibility segments should be accumulated by type of resource.

Outputs produced by responsibility segments should be accumulated and, if practicable, measured in

units. The full costs of resources that directly or indirectly contribute to the production of outputs should

be assigned to outputs through costing methodologies or cost finding techniques that are most

appropriate to the segment’s operating environment and should be followed consistently.

The cost assignments should be performed by the following methods listed in the order of preference: (a)

directly tracing costs wherever feasible and economically practicable, (b) assigning costs on a cause-and-

effect basis, or (c) allocating costs on a reasonable and consistent basis.

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118. In the section of this document relating to “Responsibility segments,” it was explained that:

“A responsibility segment is a component of a reporting entity, that is responsible for

carrying out a mission, conducting a major line of activity, or producing one or a group of

related products or services.” The accumulation of costs by responsibility segments does

not mean that each responsibility segment must have its own accounting system. The

reporting entity may have a centralized accounting system, but the system should be

capable of identifying costs with responsibility segments.

119. This standard also requires that the accumulated costs be classified by type of resource,

such as costs of employees, materials, capital, utilities, rent, etc. When appropriate and cost

effective, information on quantitative units related to various cost categories should be

maintained. For example, staff-days may be reported for staff salaries and benefits, and

gallons of gasoline consumed for gasoline costs. The quantitative units are useful for cost

assignments, and are indispensable for measuring efficiency in using resources.

Cost Assignment

120. The term “cost assignment” refers to the process that identifies accumulated costs with

reporting periods and cost objects. The assignment of costs to time periods is to recognize

costs either as expenses or assets for each reporting period. It is governed by accounting

standards on recognition of assets and expenses, and will not be addressed in this

document. This section addresses cost assignment to cost objects. The word “assignment”

used in this document includes various methods of attributing costs, such as direct tracing,

cause-and-effect basis, and cost allocations.

121. The term “cost object” refers to an activity or item whose cost is to be measured.

In a

broad sense, a cost object can be an organizational division, program, activity, task,

product, service, or customer. However, the purpose of cost accounting by a responsibility

segment is to measure the costs of its outputs. Thus, the final cost objects of a responsibility

segment are its outputs: the services or products that the segment produces and delivers,

the missions or tasks that the segment performs, or the customers or markets that the

responsibility segment serves. There may be intermediate cost objects that are used in the

course of the cost assignment process.

122. Some responsibility segments of an entity may provide supporting services or deliver

intermediate products to other segments within the same entity. The costs of the supporting

services and intermediate products should be assigned to the segments that receive the

services and products. This is referred to as the intra-entity cost assignments. Also, in

accordance with the inter-entity cost standard discussed in the preceding section, an entity

Some literature, the CASB pronouncements for example, use the term “cost objective” for the same meaning.

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should recognize inter-entity costs for goods and services received from other federal

entities. The inter-entity costs should also be assigned to the responsibility segments that

use the inter-entity services and products.

123. Thus, with respect to each responsibility segment, the costs that are to be assigned to

outputs include: (a) direct and indirect costs incurred within the responsibility segment, (b)

costs of other responsibility segments that are assigned to the segment, and (c) inter-entity

costs recognized by the receiving entity and assigned to the segment. If a responsibility

segment produces one kind of output only, costs of resources used to produce the output

are assigned to the output.

124. This standard is intended to establish a principle, rather than a methodology, for cost

assignment. Also cost assignments may be performed in cost findings and studies or may

be performed within a system on a regular basis. In principle, costs should be assigned to

outputs in one of the methods listed below in the order of preference:

(a) Directly tracing costs wherever economically feasible;

(b) Assigning costs on a cause-and-effect basis; and

125. These principles apply to all levels of cost assignments including:

(1) assigning inter-entity costs to segments, (2) assigning the costs of support services and

intermediate products among segments of an entity (the intra-entity cost assignments), and

(3) assigning direct and indirect costs to outputs.

Directly tracing costs to outputs

126. Direct tracing applies to resources that are directly used in the production of an output.

Examples of such resources include materials that are used in the production, employees

who directly worked on the output, facilities and equipment used exclusively in the

production of the output, and goods or services received from other entities that are directly

used in the production of the output.

127. The method of direct cost tracing usually relies on the observation, counting, and/or

recording of the consumption of resource units, such as staff hours or days that are spent on

a project or assignment, or gallons of fuel consumed in a transport mission. Direct tracing

also applies to specific resources that are dedicated to particular outputs.

128. Direct cost tracing often minimizes distortion and ensures accuracy in cost assignments.

However, it can be a relatively costly process. It should be applied only to items that account

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for a substantial portion of the cost of an output and only when it is economically feasible.

For example, it is usually unnecessary to trace the cost of office supplies (pens, papers,

computer disks, etc.) to various activities or outputs. The cost of so doing usually outweighs

the benefit of the increased accuracy in assigning the resources.

Assigning costs on a cause-and-effect basis

129. For the costs that are not directly traced to outputs, it is preferable that they be assigned to

them on a cause-and-effect basis. As mentioned earlier, the ultimate cost objects of a

responsibility segment are its outputs. For costs that are not traced to the ultimate objects

(outputs), intermediate objects can be established as links between resource costs and

outputs. The links reflect a cause-and-effect relationship between resource costs and

outputs. Costs that have a similar cause-and-effect relationship to outputs can be grouped

into cost pools. (This similar relationship is referred to in some literature as the “cost pool

homogeneity concept.”)

130. Activities or work elements that contribute to or support the production of outputs are

commonly used as intermediate objects. This is based on the premise that on one hand,

outputs require the performance of certain activities, and on the other hand the activities

cause costs. Thus, an activity is considered a linkage between the cause and the effect.

(See also, discussions on Activity-Based Costing later in this section.) In its policy

statement, the Cost Accounting Standards Board expressed a similar view:

“The preferred presentation of the relationship between the pooled cost and the benefiting cost objectives is a

measure of the activity (input) of the function or functions represented by the pool of cost. This relationship can be

measured in circumstances where there is direct and definitive relationship between the function or functions and

the benefiting cost objectives.”

131. For example, a computer technology department provides technical support to other

departments of an organization. The costs of the department may be assigned to other

departments on a cause-and-effect basis through two steps. In the first step, the costs are

assigned to the activities of the department, such as hardware installation and maintenance,

software design and installation, or programming adjustments. In the second step, the costs

of these activities are further assigned to other departments based on their consumption of

the technical services.

132. Sometimes, an intermediate product, rather than an activity, can be used as a link between

the costs and outputs. For example, a hospital laboratory’s costs can first be assigned to

Cost Accounting Standards Board, Restatement of Objectives, Policies and Concepts, par. 2915.

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various medical tests it runs. The costs of the tests can then be assigned to the operating

units of the hospital that ordered the tests.

Allocating costs

133. Sometimes, it might not be economically feasible to directly trace or assign costs on a

cause-and-effect basis. These may include general management and support costs,

depreciation, rent, maintenance, security, and utilities associated with facilities that are

commonly used by various segments.

134. These supporting costs can be allocated to segments and outputs on a prorated basis. The

cost allocations may involve two steps. The first step allocates the costs of support services

to segments, and the second step allocates those costs to the outputs of each segment. The

cost allocations are usually based on a relevant common denominator such as the number

of employees, square footage of office space, or the amount of direct costs incurred in

segments.

135. Suppose the total cost of a personnel department for a fiscal year is $500,000, and it is

allocated to two segments based on the number of employees of the two segments:

segment A has 300 employees, and segment B has 200 employees. On the prorated basis,

segment A should be allocated 60 percent, or $300,000 of the personnel cost, and segment

B should be allocated 40 percent, or $200,000 of the personnel department cost. The

allocation is shown below:

Table 3: The Allocation of the Personnel Dept. Costs

136. For cost allocation purposes, indirect costs may be grouped into pools, and each pool is

subject to one allocation base. Costs grouped into one pool should have similar

characteristics. The allocation base should be used consistently to allow cost comparison

from one period to another.

137. Cost allocation is a relatively simple method of assigning indirect costs to cost objects.

Users of the cost information should be aware that distortions in product costing often result

from arbitrary cost allocations. In most cases, there is little correlation between an indirect

cost and the allocation base, and the allocation is arbitrary. To assist cost analyses and cost

Segment Employees Percent Allocated amount

A 300 60 $300,000

B 200 40 $200,000

Total 500 100 $500,000

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findings, cost accounting should segregate costs that are traced or assigned to outputs from

costs that are allocated to outputs.

Assigning common costs

138. Facility and personnel resources may be shared by two or more activities either at the same

time or in different times during a fiscal year. For example, a military aircraft maintained for

war readiness may be used in peacetime to transport cargo. As another example, a plant

may be used to process two or more products.

139. The cost assignment principles discussed in this section should apply to assigning costs to

activities or outputs that share the use of resources. Costs that can be traced to each of the

activities (or outputs) should be assigned to them directly. These include direct operating

costs of each of the activities. For the military aircraft used in peacetime to transport cargo,

for example, the costs of fuel and supplies, additional personnel who worked on the cargo,

and other costs incidental to the transportation should be directly assigned to the

transportation services.

140. To determine the full cost of each of the activities or outputs that share resources, indirect

common costs should be assigned to those activities. The term “common costs” refers to

the costs of maintaining and operating facilities and other resources that cannot be directly

traced to any one of the activities or outputs that share the resources.

Common costs

should be assigned to activities either on a cause-and-effect basis, if feasible, or through

reasonable allocations.

141. Sometimes management may find it useful to designate primary and secondary activities

that share resources. Primary activity is the primary purpose or mission for which the

resources are made available. Secondary activities are those activities that are performed

only if they will not interfere with the primary activity. Management can then determine two

types of costs: (1) the costs that are necessary for the primary activity and are unavoidable

even without the secondary activities, and (2) the costs that are caused by the secondary

activities and are incremental to the costs of the primary activity. This type of cost

information can be produced through cost findings, and may help management in making

resource allocation and capacity utilization decisions.

This definition is adapted from Statement No. 1 on Management Accounting: Management Accounting Glossary,

published by the National Association of Accountants (Montvale, New Jersey: 1991), page 15.

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Cost-benefit considerations

142. Throughout the discussions of this section, it is stated that a cost accumulation and

assignment method would be used when it is economically feasible. A method is

economically feasible if the benefits resulting from implementing the method outweigh its

costs. It is not advantageous to use a costing method if it requires a large amount of

resources and yet produces information of little value to users.

143. As a general rule, directly tracing costs and assigning costs on a cause-and-effect basis are

more expensive than cost allocations, because they require detailed analyses and record-

keeping for costs and activities. However, they are preferable because they produce more

reliable cost information than cost allocations.

Selecting A Costing Methodology

144. This standard does not require the use of a particular type of costing system or costing

methodology. Federal entities are engaged in a broad range of diverse operations. A costing

system appropriate for one type of operation may not be appropriate for other operations. At

many federal agencies, cost accounting practices are either relatively new or experimental.

It is too early to tell which cost systems are best for specific types of operations. As

experience and research in cost accounting progress, reporting entities and responsibility

segments may find a preferred costing methodology for their operations.

145. Agency and program management is in the best position to select a type of costing system

that would meet its needs. In making the selection, management should evaluate alternative

costing methods and select those that provide the best results under its operating

environment.

146. The standard requires that a costing methodology, once adopted, be used consistently.

Consistent use provides cost information that can be compared from year to year. However,

this requirement does not preclude necessary improvements and refinements to the system

or methodology, so long as the effect of any change is documented and explained. On the

contrary, improvements are encouraged.

147. Several costing methodologies have been successful in the private sector and in some

government entities. Four are briefly described below for agency consideration. It should be

noted in particular that activity-based costing has gained broad acceptance by

manufacturing and service industries as an effective managerial tool. Federal entities are

encouraged to study its potential within their own operations. In the following paragraphs,

activity-based costing will be introduced with other well known costing methodologies,

namely job order costing and process costing. Standard costing is also mentioned as an

important cost management tool. It is important to note that those costing methodologies are

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not mutually exclusive. Both activity-based costing and standard costing can be applied to

job order or process costing systems.

Activity-based costing (ABC)

148. ABC focuses on the activities of a production cycle, based on the premises that (a) an

output requires activities to produce, and (b) activities consume resources. ABC systems

use cost drivers to assign costs through activities to outputs. The ABC cost assignment is a

two-stage procedure. The first stage assigns the costs of resources to activities and the

second stage assigns activity costs to outputs. The procedure is illustrated in the following

figure.

Figure 2: The Activity-Based Two Stage Costing Procedure

149. Implementing an ABC system requires four major steps: (1) identify activities performed in a

responsibility segment to produce outputs, (2) assign or map resources to the activities, (3)

identify outputs for which the activities are performed, and (4) assign activity costs to the

outputs. Each of the steps is briefly explained below.

(1) Identify activities.

This step requires an in-depth analysis of the operating processes of

each responsibility segment. Each process may consist of one or more activities

required by outputs. Activities may be classified into unit-level, batch-level, product

The figure and the accompanying discussions are based on Robin Cooper, Robert S. Kaplan, Lawrence S. Maisel,

Eileen Morrissey, and Ronald M. Oehm, Implementing Activity-Based Cost Management

(Montvale, NJ: Institute of

Management Accountants, 1992), pages 9-13.

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sustaining, and facility sustaining activities.

Management may combine related small

activities into larger activities to avoid excessive costing efforts.

(2) Assign resource costs to activities.

This step assigns resource costs to the activities

identified in step 1. The resource costs include direct and indirect costs usually

recorded in general ledger accounts. Depending on feasibility and cost-benefit

considerations, resource costs may be assigned to activities in three ways: (a) direct

tracing; (b) estimation based on surveys, interviews, or statistical sampling; or (c)

allocations.

(3) Identify outputs.

This step identifies all of the outputs for which activities are performed

and resources are consumed by a responsibility segment. The outputs can be

products, services, or customers (persons or entities to whom a federal agency is

required to provide goods or services). Omitting any output would result in

overcharging costs to other outputs.

(4) Assign activity costs to outputs.

In this step, activity costs are assigned to outputs using

activity drivers. Activity drivers assign activity costs to outputs based on individual

outputs’ consumption or demand for activities. For example, a driver may be the

number of times an activity is performed in producing a specific type of output (the

transaction driver), or the length of time an activity is performed (the duration driver).

150. ABC can be used in conjunction with job order costing or process costing. For example,

making direct loans to the public involves a series of processes, such as loan origination,

credit review for individual applicants, preparing loan documents, valuation of collateral,

making loan disbursements, computing fees and periodic payments, keeping records, and

making collections. These are the “first category” activities that directly affect individual

loans. ABC can be applied to this category of activities.

151. The direct loan operations also involve “second category” activities, such as those

performed by loan officers to review and assess a portfolio of loans and make policy

changes that affect an entire portfolio. If ABC is not used, the costs of the loan officers may

be allocated to direct loans based on the number of loans disbursed, or based on the staff

hours spent on processing all the loans. However, such an allocation tends to be arbitrary,

because some loans require more of their time than others. Under ABC, the costs of loan

officers would first be assigned to their portfolio review and workout activities that they

perform, then the activity costs would be assigned to the groups of loans for which the

activities are performed.

Cooper, Kaplan, et al. page 20.

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152. A major advantage of using ABC is that it avoids or minimizes distortions in product costing

that result from arbitrary allocations of indirect costs. By tracing costs through activities,

ABC provides more accurate service or product costs. Experience in the private sector

shows that by providing accurate cost measures, ABC has helped improve product costing,

strategic pricing, and profit planning.

153. Also important is that ABC encourages management to evaluate the efficiency and cost-

effectiveness of activities. Some ABC systems rank activities by the degree to which they

add value to the organization or its outputs. Managers use such value rankings to focus their

cost reduction programs. ABC encourages management to identify and examine (a) what

activities are really needed (value-added activities) in order to accomplish a mission, deliver

a service, or meet customer demand, (b) how activities can be modified to achieve cost

savings or product improvements, and (c) what activities do not actually add value to

services or products (non-value-added activities). ABC integrates with cycle time analysis

and value-added analysis.

Job order costing

154. Job order costing is a costing methodology that accumulates and assigns costs to discrete

jobs. The word “jobs” refers to products, projects, assignments, or a group of similar outputs.

155. Each job has a number or code to accumulate costs. Resources spent are identified with the

job code. Costs are traced to individual jobs to the extent economically feasible. Costs that

cannot be directly traced are assigned to jobs either on a cause-and-effect basis or

allocation basis.

156. Job order costing is appropriate for responsibility segments that produce special order

products, or perform projects and assignments that differ in duration, complexity, or input

requirements. Typical situations in the federal government in which job order costing would

be appropriate are legal cases, audit assignments, research projects, and repair work for

ships, aircraft, or vehicles.

Process costing

157. Process costing is a method that accumulates costs by individual processing divisions

(organization divisions that perform production processes). These processing divisions are

involved in a continuous production flow, with each division contributing towards the

completion of the end products. The output of a processing division either becomes the

input of the next processing division or becomes a part of the end product.

158. Each division accumulates costs, assigns the costs to its outputs, and calculates the unit

cost of its output. For each period, divisions prepare a cost and production report, showing

the costs, the completed units, and the work-in-process volume. When a certain number of

completed units are transferred from a division to the next division, the costs of those units

are also transferred and are eventually incorporated into the costs of the end product. Thus,

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the cost flow follows the physical flow of the production. The unit cost of the end product is

the sum of the unit costs of all the divisions.

159. Process costing is appropriate for production of goods or services with the following

characteristics: (a) the production involves a regular pattern of process, (b) its output

consists of homogeneous units, and (c) all units are produced through the same process

procedures. In the private sector, process costing is used by such industries as flour mills,

steel foundries, oil refineries, and chemical processing plants. In government, it may be

used by some activities that involve repetitive process procedures to deliver a large volume

of similar goods or services. An example would be making entitlement benefit payments,

which involves a series of consecutive processes for reviewing applications to establish

their eligibility, computing the amount of benefits, and issuing checks.

Standard costing

160. Standard costs are carefully predetermined or expected costs that can be applied to

activities, services, or products on a per unit basis. Horngren describes standard costing as

follows:

“A set of standards outlines how a task should be accomplished in nonfinancial terms (minutes, board feet) and

how much it should cost. As work is being done, actual costs incurred are compared with standard costs for

various tasks or activities to reveal variances. This feedback helps discover better ways of adhering to standards,

of altering standards, and of accomplishing objectives.”

161. Many organizations frequently review and update the standards to assure that they

encourage improvements in efficiency and are within an attainable range.

162. Standard costing helps managers to formulate budgets, control costs, and measure

performance. It can be used in conjunction with job order costing, process costing, and

activity-based costing. It can be applied to specific outputs or activities, and it can also be

applied to a responsibility segment in aggregate by comparing total actual costs with total

standard costs based on outputs produced within a certain time period. Typical situations in

the federal government in which standard costing would be appropriate are operations that

produce services or products on a consistently repetitive basis. Agencies are encouraged to

use standard costing in those situations.

Horngren, Charles T. and George Foster, Cost Accounting, A Managerial Emphasis, 7th ed. (Prentice Hall,

Englewood Cliffs: New Jersey, 1991), page 222.

The provisions of this Statement need not be applied to information if the effect of applying

the provision(s) is immaterial. Refer to Statement of Federal Financial Accounting Concepts

1, Objectives of Federal Financial Reporting, chapter 7, titled Materiality, for a detailed

discussion of the materiality concepts.

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Appendix A: Basis For Conclusions

This Statement may be affected by later Statements. The FASAB Handbook is updated annually

and includes a status section directing the reader to any subsequent Statements that amend this

Statement. Within the text of the Statements, the authoritative sections are updated for changes.

However, this appendix will not be updated to reflect future changes. The reader can review the

basis for conclusions of the amending Statement for the rationale for each amendment.

The Nature of Concepts and Standards

163. The difference between accounting concepts and standards is significant. Statements of

concepts are more general than statements of standards. Standards are intended to be

specific guidance and authoritative in nature. Concepts generally do not contain specific

recommendations that would, when issued by the Board’s sponsors, become authoritative

requirements for federal agencies. Concepts, instead, provide general guidance both to the

Board and others. They are also intended to help preparers and users of financial

information better understand federal accounting and financial reporting. While the

differences can be easily stated, in reality the line between concepts and standards is often

broad and presents many gray areas for interpretation.

164. When the Board began the project on managerial cost accounting, it anticipated the

issuance of a recommended Statement of Concepts. Given the meager use of cost

accounting within many federal agencies, a Statement of Concepts would provide both the

Board and preparers of federal financial reports with overall guidance in the area and an

indication of the future direction the Board might take in developing standards. However, as

the Board and staff began working on the project, it became clear that action was needed to

recommend standards for the development of cost information.

165. Cost accounting standards were needed because users of financial information, especially

taxpayers and members of Congress, began putting more emphasis on the cost of

government programs, products, and activities. The efforts to reduce government spending,

control the deficit, and improve government functions necessitated information about the

true costs of government. In addition, passage of the CFO Act and the GPRA required

agencies to provide cost information as a part of improving their financial management and

reporting. Furthermore, the NPR issued a recommendation that the Board move rapidly to

recommend cost accounting standards.

166. The Board established the Cost Accounting Task Force to provide advise and guidance on

the cost accounting project. On the task force were many individuals knowledgeable about

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cost accounting in the private sector as well as the limited federal cost accounting activities.

The task force also recommended the establishment of cost accounting standards.

167. The Board issued the exposure draft as a recommended statement of standards. The Board

knew, however, that since cost accounting is relatively new in the federal environment, the

final statement necessarily would contain some conceptual material. Although the exposure

draft did not present any direct questions concerning whether parts of the draft should be

viewed as concepts, the issue did arise in public hearings held in November 1994, and

January 1995. In addition, a few respondents who mailed in their comments addressed the

point.

168. Most of those commenting on the issue stated that they viewed the exposure draft as being

somewhat conceptual in nature. Many of those thought that this was appropriate and

supported the document and the conceptual material it presented. A few respondents were

concerned about the ability to audit some of the standards because of the conceptual nature

of the document. Several suggested that the final statement be segregated into concepts

and standards and both be issued in one statement.

169. The Board decided that some parts of the final statement would contain information that

should be presented as concepts while other parts would be better presented as standards.

Therefore, the final statement should be a “hybrid” issuance containing both concepts and

standards. The title of the document was changed to “Managerial Cost Accounting

Concepts and Standards for the Federal Government.” (The Board decided that the material

presented in the exposure draft as the first standard that addressed the relationship among

managerial cost accounting, financial reporting, and budgeting should be presented as

concepts. The other materials were more in the nature of standards.)

Relationship Among Cost Accounting, Financial Reporting, And Budgeting

170. The Board considers it important for financial preparers and users of financial reports to

understand the relationship of cost accounting to the more traditional areas of general

financial accounting, financial reporting, and budgeting. It views cost accounting as a basic

and integral part of an entity’s financial management system. Therefore, the Board included

a standard on this relationship within the exposure draft.

171. The standard addressed the role of managerial cost accounting in financial management

and explained how it provides cost information relevant to budgeting, financial reporting,

management control, and many decision making processes. The standard discussed the

use of a common data source for cost accounting, financial accounting, and budgeting. It

explained how the costs may be determined using different bases of accounting and

different recognition and measurement methods depending upon the intended use of the

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information. It also emphasized the need for reconciliation of cost data which may be

presented differently in various financial reports. The standard stated that all cost

information, regardless of how presented, should be traceable back to the original common

data source.

172. Most exposure draft respondents who provided comments on this standard stated that the

level of detail presented was about right given the desire of the Board to address cost

accounting at a high level. Most respondents agreed with the need to draw cost accounting

data from a common data source that is also the source of financial and budgetary data.

Some respondents were concerned that the use of the term “data source” was too closely

allied with automated or computerized operations and that the term may be misinterpreted.

The Board, however, believes that the term is adequately explained. In fact, the exposure

draft clearly stated that this term was not meant to imply the use of computerized systems

for source information.

173. Data reconciliation for reports containing cost information developed on different bases of

accounting or using different recognition or measurement methods received overwhelming

support from respondents to the exposure draft. They said that the ability to reconcile

differing cost information is necessary to ensure data integrity, avoid confusion on the part of

financial statement users, and support stewardship responsibilities.

174. Many who commented on whether the exposure draft should be viewed as a statement of

concepts or a statement of standards implied that this particular standard on relationships of

cost accounting to other financial management functions was basically conceptual in nature.

The Board agreed and concluded that this section is more in the nature of an explanation of

how cost accounting provides useful information and how it fits in with the overall financial

management system as opposed to a standard which places a requirement on an entity.

The Board decided that this material would be better presented in the final statement as

recommended concepts.

Requirement For Cost Accounting

175. The cost accounting task force recommended that a standard be included in the exposure

draft requiring each reporting entity to establish cost accounting systems and procedures for

its activities. They believed this was necessary to ensure the generation of required cost

information.

176. The Board agreed to include the standard in the exposure draft. The standard defined

“system” in a broad way as simply an organized grouping of methods and activities

designed to consistently produce reliable cost information. The explanations and

discussions section of the exposure draft contained information on several factors that

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would help managers decide how complex and sophisticated their cost accounting system

should be. It noted that the system could be constrained by the (1) nature of the entity’s

operations, (2) precision needed in cost information, (3) practicality of data collection and

processing, (4) availability of electronic data handling, (5) expected cost of the system itself,

and (6) any specific management information needs.

177. The exposure draft also listed ten minimum criteria that should be met by all managerial

cost accounting systems. Four of these were related directly to the other standards in the

exposure draft (responsibility segments, full costing, costing methodology, and unused

capacity costs). The six remaining criteria were concerned with ensuring that the cost data

produced was reliable, consistent, and useful. These criteria were (1) ensuring the ability to

assist in measurement of performance, (2) reporting information on a timely and consistent

basis, (3) integrating cost accounting with the standard general ledger, (4) determining a

reasonable and useful level of data precision, (5) accommodating special information needs

of management, and (6) documenting the system through a manual or handbook. The

standard also allowed for the use of cost finding techniques and special cost studies or

analyses.

178. A large number of respondents to the exposure draft supported the requirement for cost

accounting systems. They stated that such a requirement is necessary to ensure that

appropriate cost data are recorded. They also said that having a requirement for cost

systems will help agencies to more easily meet the requirements of the CFO Act and the

GPRA. Some qualified their support by stating that the standard should allow an exemption

for small entities since establishment of a full cost accounting system may not be cost-

beneficial to them. The Board decided that such an exemption would be inappropriate since

the standards should apply to all federal activities. Furthermore, it should be far easier for

small entities to perform managerial cost accounting in most cases.

179. Those who were negative toward the standard provided several reasons. Several

expressed concern about whether accounting standard-setting bodies should require or

determine how accounting data are produced. They noted that other accounting standard-

setting organizations have stated only what information is required and how that information

is displayed in financial statements, not how the information is developed.

180. The Board believes that it should not be constrained by what other standard-setters do.

Other standard-setters so far have concerned themselves mainly with entities’ external

reporting. This is understandable because their mission is to assure that the financial

position and results of operations are presented in a fair, reliable, and consistent manner to

financial statement users who are external to the reporting entity.

181. FASAB is different in that it has determined that some of the users of federal government

financial reports are internal to the government. Given the nature and size of the federal

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government, internal users often do not have the same type of access to cost information

that may be available in commercial enterprises. In addition, the Board views cost

accounting information as vital to both internal and external users. The Board has previously

determined in its Objectives of Financial Reporting that cost information should be reported

to meet the needs of Congress, federal executives, and others.

182. Some respondents to the exposure draft were concerned that the requirement for a cost

accounting system, along with the system criteria, would not allow management enough

flexibility. They seemed to consider the requirement for a system to mean that cost

accounting activities had to be automated with computers and that software had to be

developed and employed in a “full-blown” system, as one put it. They believe that such an

elaborate system may not be needed in some cases where informal procedures or methods

would suffice.

183. The Board does not intend to prescribe an elaborate managerial cost accounting system for

every federal organization. It believed that the standard proposed in the ED was sufficiently

broad to allow managerial flexibility in the system design. However, the Board does

recognize that the term “system” may connotate to some a requirement for computerization

and sophisticated methodologies.

184. Others stated that establishing the requirement for cost systems should be the responsibility

of OMB or JFMIP. Some of the respondents were concerned about the degree to which the

standard may overlap with JFMIP’s responsibility to set requirements for cost accounting

systems. The NPR recommends setting requirements for cost accounting systems as a

responsibility of JFMIP, while asking the Board to provide the cost accounting standards.

185. The Board proposed the requirement for systems to ensure that cost information is

produced and reported in a reliable and consistent manner, and emphasized that this was

the intent. The point is not whether the information is produced through the use of a system

or through other techniques. The Board believes that, in many cases, cost accounting

systems will be established as a natural consequence of requiring cost information. Many

government agencies are very large and complex organizations, and it is unrealistic to think

that they can develop cost data without relying on a system to do so. Other small agencies

or reporting entities may not need a system to develop cost data in a regular, consistent,

and reliable manner.

186. The Board, therefore, changed the standard to emphasize producing cost accounting

information in a reliable and consistent manner. This can be done through the use of cost

Office of the Vice President, Improving Financial Management, Accompanying Report of the National Performance

Review (September 1993), page 24.

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accounting systems or cost finding techniques. In either case, the main intent of the original

standard is preserved. In addition, the concerns expressed over whether the Board or some

other organization should establish the requirement for cost “systems” are solved.

Responsibility Segments

187. As stated in the ED, a responsibility segment is a component of a reporting entity that is

responsible for carrying out a mission, conducting a major line of activity, or producing one

or a group of related products or services.

188. The proposal for using responsibility segments in the ED was based on the view that most

federal departments and agencies are engaged in more than one line of activity, or

producing more than one type of service or product. Furthermore, the activities that an

agency performs may differ from each other significantly in required resources and

operations. The ED used the Department of Veterans Affairs (VA) as an example. Among its

activities, VA administers hospitals and nursing homes to provide health care to veterans,

and it also administers direct home loan and loan guarantee programs. These lines of

activities are significantly different in operation patterns. The Board believes that for entities

that are engaged in diverse activities, identifying responsibility segments is necessary for

identifying resources consumed by a distinct line of activity with the outputs of that activity.

189. A majority of respondents supported the requirement for responsibility segments and

agreed with the advantages of the requirement. They expressed the view that segmentation

provides a basic framework to trace and assign costs to outputs. They also believed that

segmentation provides management with the flexibility of choosing a costing methodology

that is best suited for a line of activity. The respondents also stated that information

generated by responsibility segments can be used to measure performance and to assess

accountability.

190. Several respondents, however, presented arguments against using responsibility segments.

One such argument was that responsibility segments would constitute an unnecessary layer

that conflicts with financial reporting and budgeting systems. The Board disagrees with this

view. A responsibility segment is not, and should not be, an additional layer to the

organization and the budget structure. It is an accounting mechanism to capture data

generated in operations by various components of an organization in its existing structure.

Organization and budget structures can be changed for better management but not for the

sake of accounting. Accounting may influence but cannot dictate such changes.

191. The Board believes that accounting by segment will help provide information useful to

program managers and other users of financial reports. Entity-wide financial reports provide

information on the overall financial position and operating results of an entity in aggregate.

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Such reports, although useful for many purposes, are not sufficient for cost management. A

fundamental undertaking of managerial cost accounting is to match costs with activities and

outputs. The purpose of segmentation is to segregate entity-wide data by major lines of

activities and their outputs. Information related to each segment should tell managers and

other users of financial reports about the segment’s specific outputs, the activities

performed, and resources consumed to produce the outputs.

192. Furthermore, segment-based reporting need not be in conflict with entity-wide financial

reporting. They can use a common source of data, such as accounting data collected by the

standard general ledger or the budget execution reports. To perform segment-based

accounting and reporting, the general accounting or budget execution data can be traced

and assigned to segments. The Statement of Federal Financial Accounting Concepts No. 2,

Entity and Display, discusses a reporting approach similar to the segment-based accounting

and reporting:

“With some organizations, and even suborganizations, the activities of one or more programs or other

components are as important to the readers of financial statements as are activities of the entity as a whole. This

would be particularly true for a department composed of many bureaus, administrations, agencies, services, etc.,

and particularly if their programs are dissimilar. In those instances, consideration should be given to the

preferability of reporting the assets, liabilities, revenues, expenses, etc., of both the significant components

individually and of the entity in its entirety.”

193. Another argument against requiring responsibility segments was that the requirement is

overly prescriptive and would constrain agency management from selecting among various

cost collection methods. The Board believes the standard gives management adequate

flexibility in structuring cost accounting. As the standard states, it is for the management of

each entity to decide how segments should be defined, and how similar products and

services can be grouped into one segment.

194. Furthermore, segments are the largest components of an entity. Management has the

flexibility to use any cost collection method within each segment. Within a segment,

management may define sub-units, functions, projects, business processes, activities, or a

combination of them as cost centers to accumulate costs. The costs accumulated at lower

levels can then be aggregated to the segment level.

195. In fact, a segment may contain multiple levels of responsibility or cost centers. For example,

if veterans health care is defined as one of the DVA’s responsibility segments, this segment

may define its hospitals, clinics, and nursing homes as responsibility centers. Each hospital,

clinic, and nursing home may further define their functional units, activities, or business

processes as cost centers.

FASAB Statement of Recommended Accounting Concepts 2, Entity and Display, par. 75.

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196. Some respondents correctly pointed out that requiring broad responsibility segments, rather

than prescribing traditional cost centers, provides opportunity for entities to use activity-

based costing or any other costing methods that they may find appropriate.

197. Several respondents who supported the use of responsibility segments interpreted the

wording of the proposed standard as requiring that each segment perform managerial cost

accounting. They pointed out that for some entities, it is more effective and economical to

perform centralized managerial cost accounting. Such centralized accounting is capable of

accumulating costs by segments and assigning costs among them. The respondents

requested that the wording be revised to provide this flexibility.

198. The Board agrees with this request. The Board believes that entity management should

have the discretion to decide whether managerial cost accounting is performed at the entity

or segment level, so long as the segment cost information is provided to managers and

other users. Thus, the standard recommended in this statement does not require that

responsibility segments perform managerial cost accounting.

Full Cost

199. As stated in the ED, the full cost of an output produced by a responsibility segment is the

sum of direct and indirect costs that contribute to the output, including the costs of

supporting services provided by other segments and entities.

200. The outputs of a responsibility segment are considered as cost objects.

However, in most

circumstances, the full costs of intermediate objects, such as activities, processes, projects,

programs, or organization units, must also be measured in order to derive the full costs of

their outputs. (See ED Par. 173) The full cost information related to outputs as well as those

intermediate objects are useful in measuring efficiency and cost-effectiveness.

Usefulness of full cost information

201. Program evaluation and authorization. Most respondents supported the full cost

standard. They recognized that it is particularly important to determine and report the full

cost of a program. Information on full costs of programs can be used in program

evaluations. Such evaluations typically relate the full costs of programs to their outputs and

outcomes. Decision-makers in the Congress and the federal government at all levels as well

“Cost object” is defined as an activity, output, or item whose cost is to be measured. In a broad sense, a cost object

can be an organizational division, a function, task, product, service, or a customer. See Glossary.

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as the public should be provided with information on the full costs of programs and their

outputs. The full cost information, when used with information on program outputs and

outcomes, can aid the Congress and federal executives in making decisions on program

authorization and modifications.

202. Cost awareness. Most respondents also agreed that the standard has the advantage of

promoting cost awareness. Entity and segment managers should be aware of the costs that

are incurred or assigned to their operations. Without the awareness, managing and

controlling costs are impossible. The full cost information has not been available and will not

likely to be without an accounting standard requiring it.

203. Setting fees and prices for government goods and services. Many respondents agreed

that full cost should be considered as a primary basis for setting fees and reimbursements

for government goods and services. As pointed out in the ED, it is a federal policy that, with

certain exceptions, user charges (prices or fees) should be sufficient to recover the full cost

of goods, services, and resources provided by the federal government as sovereign.

The

policy further states that when the government sells goods and services under business-like

conditions rather than in a sovereign capacity, user charges should be based on market

prices and may yield a net revenue in excess of the full cost. The objectives of the policy are

to: (1) ensure that government goods and services are provided on a self-sustaining basis,

(2) promote efficient allocation of national resources, and (3) allow fair competition with

comparable goods and services provided by the private sector.

204. To implement the policy, full cost information is necessary. Only with reliable full cost

information can management ensure that user charges fully recover the costs.

Even in

some exceptional cases in which user charges are exempted or restricted by law, agencies

that provide the goods and services would nevertheless need the full cost information to

assess the extent to which costs are not recovered.

205. Making cost comparisons. Respondents agreed that the full cost of outputs provides a

valid basis for cost comparisons. One of them emphasized the importance of calculating the

unit cost of output on the full cost basis. The Board agrees with his view. If an output can be

measured in units, its unit cost should be calculated on the full cost basis.

OMB Circular No. A-25, User Charges.

The standard of determining full cost discussed in this document, however, should not be construed as a standard for

setting fees, prices, and reimbursements. Federal entities should comply with laws and regulations related to pricing

policies in general and for specific types of goods and services. Those laws and regulations (including OMB Circular A-

25) may prescribe costing requirements other than the full cost standard discussed in this document. Full cost defined

by this standard can serve as a point of reference for managerial decisions. However, it is not intended to supersede

any costing concept that management is required or permitted by law to use in pricing goods and services.

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206. The unit cost of a service or product, calculated on a full cost basis, can be compared with a

similar service or product produced by other entities either in the federal government or in

the private sector. The comparison would not be valid if it is not conducted on a full cost

basis.

207. One of the available cost management tools is trend analysis. In trend analysis, unit costs of

a service or product over a number of consecutive periods are examined to find a trend of

increases or decreases. This analysis can be valid only when the unit costs of all periods

are measured on a consistent basis, such as the full cost basis. When the full cost basis is

used, the analyst can further examine the components of the unit cost, such as direct labor

and material costs, overhead costs, and costs of services received from other segments or

entities. Through examining the various components of the full unit cost, program managers

can pinpoint specific areas that contributed to cost increases or decreases.

208. If activity-based costing is used, the cost components would be associated with activities.

The trend analysis for activity-based cost components can provide information related to the

efficiency of the activities. Managers can also analyze the extent that the individual activities

add value to program outputs and objectives.

Limitations of Full Cost Information

209. Several respondents cautioned the Board against “uncritical advocacy” of full costs. They

pointed out that full cost is not relevant to all decision-making situations. They explained that

some decisions require other cost concepts such as variable, differential, or incremental

costs. Thus, some of them said that the Board should not singularly emphasize full cost.

210. The Board is aware of the notion that different cost concepts should be used for different

purposes so that the use of a cost concept is relevant to a particular decision-making

purpose. For this reason, the Board discussed the limitations and usefulness of full cost in

the ED at length. (See ED pars 133 through 146.) Quoting from Anthony and Young, the

ED pointed out that full costs are not appropriate for alternative choice decisions such as the

decision to (1) add or drop a product or service, (2) perform work in-house or contract out for

it, and (3) accept or reject a special request. For these decisions, the appropriate

information is differential costs.

211. However, the full cost standard is an accounting standard, rather than a cost analysis or

decision-making standard. It requires that full cost information be compiled and reported

through cost accounting. In no way does it limit cost analysts and decision-makers to the

Robert N. Anthony and David W. Young, Management Control in Nonprofit Organizations, 5th ed. (Burr Ridge,

Illinois: Richard D. Irwin Co., 1994) page 235.

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use of full cost alone in all situations. The Board believes that when the full cost information,

instead of any portion of it, is made available, analysts and decision-makers will have a

comprehensive data source to develop the cost concepts that they need in their analyses.

212. Some respondents pointed out that full cost requires a complex process of cost

assignments and allocations. The Board believes that the assignment of indirect costs is a

necessary procedure to obtain full cost. It can be performed through an appropriate costing

methodology. As discussed in the costing methodology section of the ED, some modern

costing methodologies are available to make rational and reliable cost assignments.

However, the Board must caution that the full cost information, like any other accounting

information, can only be as good as how it is prepared. For example, it can be unreliable or

inaccurate, if arbitrary or irrational cost allocations are used excessively. Thus, the Board

recommended a costing methodology standard. Program managers should critically review

costing methodologies and techniques used to derive the cost information.

Inclusion or Exclusion of Certain Costs

213. A number of respondents were opposed to the inclusion of accrued employee benefit costs

and costs of services provided by other entities that are not reimbursed. (The subject of

inter-entity costs will be discussed in the next section.) They argued that these costs are not

funded with their budgetary resources and are beyond their control. A large portion of

employee benefit costs, including accrued retirement benefit costs, are funded through

appropriations to trust funds managed by OPM and DoD. The Board believes that as a

principle, full cost should include the costs of all resources applied to a program, activity,

and its outputs, regardless of funding sources. For financial reporting, the Board has stated

its position that the full costs of employee pension and other retirement benefits determined

on an actuarial basis, including the amounts that are funded to the trust funds directly,

should be recognized as an expense in the employer entity’s financial reports.

The Board

does not find a good rationale to depart from this principle in managerial costing.

214. The ED states that some costs should be recognized as a period expense rather than the

costs of goods and services (output costs). Examples include the costs of “other post

employment benefits” (OPEB), reorganization costs, and acquisition costs of Federal

“mission” and “heritage” property, plant, and equipment which are recognized as expenses

at the time of acquisition.

These costs will be recognized as expenses for the period in

which the related events take place, and are referred to as “period expenses.” The ED

FASAB Exposure Draft, Accounting for Liabilities of the Federal Government (Nov. 1994), pars. 80-99, pages 32-46.

“Federal mission PP&E” and “heritage assets” are explained in FASAB Exposure Draft, Accounting for Property,

Plant, and Equipment (February 28, 1995), pars. 98-115, pages 29-33.

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explained that since these expenses do not contribute to the outputs of the period in which

they are incurred, they should not be included in the output costs.

215. The OPEB costs, for example, may be recognized as expenses for a period in which a

reduction in force or an employee injury takes place.

It is not appropriate to attribute the

entire OPEB costs to the output costs of that period. Several respondents expressed the

view that OPEB costs should be included in full cost. There is no doubt that OPEB costs, as

well as other period expenses, are part of the full cost of an entity or a program. They may

also be part of the full costs of outputs over many years in which the employees contributed

to the production of the outputs. However, they are not the production costs for the period

during which they are incurred. Thus, the Board concluded that in cost studies,

management may distribute some of the period expenses, such as OPEB costs, to outputs

over a number of past periods if (a) experience shows that the OPEB costs are recurring in

a regular pattern , and (b) a nexus can be established between the OPEB costs and the

outputs produced in those past periods. The Board finds no reason to change this position.

216. Some respondents contended that full cost should include unused capacity costs. As will be

explained in a later section on unused capacity costs, the Board has decided not to

recommend a standard on measuring unused capacity costs. Thus, to assure valid cost

comparisons, full costs should not

exclude unused capacity costs.

Controllable and Uncontrollable Costs

217. Some respondents believed that the managers of a responsibility segment should be held

accountable only for costs that they can control, and their performance should not be

evaluated for costs beyond their control. They found that the full cost reporting would

obscure the distinction between controllable and uncontrollable costs. For performance

measurement or other purposes, some entities may want to make a distinction between

controllable and uncontrollable costs with respect to an individual responsibility segment or

a cost center. The full cost information need not interfere with this distinction. This standard

does not require the use of full cost for internal reports. If some entities choose full cost for

internal reporting, the internal reports can provide a distinction between controllable and

uncontrollable costs with respect to individual segments.

218. Ultimately, most costs are controllable at a certain level of the entity. If some of them are not

controllable at a lower level of the organization, they may very well be controllable at a

higher level. Each segment should concern itself with the costs that are assigned to it on a

cause-and-effect basis. These costs are often incurred because of a segment’s demand and

FASAB Exposure Draft, Accounting for Liabilities of the Federal Government (Nov. 7, 1994), pars. 100-102, pages

47-48.

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use of services from other segments or entities. Although the service-receiving segment has

no control over the efficiency in producing the service, it can influence the costs by changing

the demand for the service. For an entity’s top management, full cost reporting provides it

with an overview of how the entity’s various costs, including the general and administrative

costs, are incurred and assigned to the entity’s segments. The full cost reporting also makes

the entity’s top management aware of the costs of services that it receives from other

entities. The management can closely review those costs and determine whether actions

are needed to control them.

Centralized Accounting

219. The proposed standard in the ED states that “Responsibility segments should be capable of

measuring the full costs of their outputs.” Several respondents stated that the full costs of

segments, programs, and their outputs can be more effectively measured by entities

through centralized accounting, rather than by individual segments. They further stated that

it would not be cost-beneficial for segments to measure and report the full costs of their

activities and outputs on a regular basis (such as monthly basis). The Board agrees that

many entities may find it more economical and effective to measure full costs through

centralized accounting. Moreover, the Board believes that it should be for entity

management to decide as to how frequently the full cost information should be made

available in its internal reports. Thus, the wording of the standard has been changed. The

full cost requirement is now limited to external reporting via general purpose financial

reports.

Costs of Outcomes

220. A respondent suggested that in addition to the full cost of outputs, the standard should also

require reporting the full cost of program outcomes. As discussed in the ED, the Board

believes that performance measurement of a program requires three major elements: the

full cost of the program, its outputs, and its outcomes. (See ED pars 37 and 38) The full cost

of a program and its outputs, once measured according to this standard can be related to

the outcome of the program to measure its cost effectiveness.

221. This standard does not require a direct measurement of the cost of outcomes because in

most instances, program outcomes need to be measured with methodologies beyond those

discussed in this document. GPRA defined “outcome measure” as an “assessment of the

results of a program activity compared to its intended purpose.”

Many programs’ policy

objectives and intended results are socio-economic or scientific in nature, or involve national

The Government Performance and Results Act of 1993, PL 103-62, sec 4.

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defense. The assessment of the program results require expert knowledge in those areas.

Thus, unlike costs and outputs, outcomes are not always measured in quantitative or

monetary terms.

222. Moreover, unlike costs and outputs that are measured for each accounting and reporting

period, such as a quarter or a year, outcome measurement may be long-term in nature. For

example, the Senate Report on GPRA states that “Outcome measurement cannot be done

until a program or project reaches a point of maturity (usually at least several years of full

operation for programs continuing indefinitely) or at completion.” Although all programs cost

money, some of them may produce positive results, while others may produce no results or

negative results.

223. Because of the complexities in measuring outcomes, the costing principles and

methodologies discussed in this document cannot be used to measure the cost of

outcomes. The Board believes that the full cost of a program and its outcome should be

measured independently, using methodologies appropriate to costs and to outcomes. Once

each of them is measured, they can then be related to review the cost-effectiveness of the

program.

Inter-entity Costs

224. It is not unusual in the federal government for one agency to provide goods or services to

another agency. Sometimes this may be required by law, and often it is a very efficient

method of conducting business for the agencies involved and for the government as a

whole. In many cases, the agency receiving such goods or services will reimburse the

providing agency in accordance with some agreed-upon price. Often, however, there is no

charge, or there is a charge that is not sufficient to cover the providing agency’s full cost.

When such “free” or lower-than-cost items are used in the production of the receiving

agency’s outputs, the result can be an understatement of the full cost of final outputs by the

receiving agency.

Survey of Non-Reimbursed Costs

225. The Board recognized that these non-reimbursed or under-reimbursed goods and services

could distort the determination of a reporting entity’s full cost of outputs, but it was uncertain

of the extent to which this occurs. To identify examples of non-reimbursed inter-entity costs,

the Board conducted a limited survey of federal agencies. Of the 22 agencies responding to

the survey request, 13 indicated that they provide some type of service or good that is not

reimbursed. These covered a wide range of activities, but most of the costs involved were

for salaries and salary-related benefits of those employees performing the work. In most

cases, the costs were funded through direct appropriations to the providing agencies;

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however, those agencies could not specifically identify the total amounts involved. Several

provided estimates, which ranged from $360 thousand dollars per year to about $180 million

per year. Several examples of non-reimbursed inter-entity activities identified in the survey

are listed below by providing entity:

• Department of Agriculture -- Provides market data, pesticide data, food specification

information, water supply forecasts, and other agricultural information. Thirty-six federal

agencies regularly receive all or some of this information.

• Department of Commerce -- Provides accounting and grant administration services,

computer access and reports, and consultation services to several agencies.

• Department of State -- Provides space and facilities for other agencies in its buildings in the

U.S. and overseas.

• General Services Administration -- In some cases, it provides policy and regulatory

development services, property management services, and contract award and

administration to other agencies without reimbursement.

• National Science Foundation -- Administers a research grant program on engineering and

computer science for the Department of Defense.

226. The Board noted that the survey was restricted to non-reimbursed costs between different

agencies. As such, the results did not necessarily represent all of the kinds and amounts of

transactions and costs between different reporting entities. The survey was also limited to

those non-reimbursed costs which the agencies could easily identify in order to respond

quickly to the questionnaire. Nevertheless, there were indications that some non-

reimbursed costs may be significant in amount.

Usefulness of Recognition

227. Some respondents to the exposure draft stated that recognition of inter-entity

costs would

have limited usefulness for managers since they cannot control the cost of items provided

by other agencies. In some circumstances, they cannot control the amounts of inter-entity

goods or services that must be used in the production of their outputs.

Full cost, as discussed in the full cost standard, contemplates both intra-entity costs and inter-entity costs applicable

to a responsibility segment. This standard elaborates on inter-entity costs. Intra-entity costing is accomplished through

the costing methodology selected for use within the reporting entity since these costs are passed among responsibility

segments.

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228. The Board realizes that recognition of non-reimbursed or under-reimbursed inter-entity

costs will not always have the same degree of usefulness for all levels of management.

However, as stated in the standard on full costs, to fully account for the costs of the goods

and services they produce, reporting entities will need to include the cost of goods and

services received from other entities. Cost reduction and control, performance evaluation,

and process improvement depend on knowledge of the full costs of producing outputs,

including production costs incurred by other federal entities. These costs are most important

for use by the entity’s top-level management (and to a lesser degree by line managers) in

controlling and assessing the operating environment and in making decisions about how

best to acquire those goods and services. Knowledge of full cost, including the extent of

inter-entity costs, is also important to external users, especially the Congress and taxpayers,

in making decisions concerning various programs and allocating resources throughout the

government.

229. In addition, the Board believes that, without the recognition of non-reimbursed and under-

reimbursed inter-entity costs, the receiving entity has little incentive to control the use of

these resources. While they may appear to be “free” to the receiving entity, the costs are

absorbed somewhere in the government. If the receiving entity were charged for these

costs, top-level management would then have more incentive to economize and control the

use of these resources as well as make better decisions concerning how and where to

acquire them. This would help reduce overall costs to the taxpayer and provide the other

benefits associated with full-costing by responsibility segment.

230. The recognition of all inter-entity costs is also important when an entity produces goods or

services that are sold outside of the federal government. For the entity to recover the

government’s full cost on the sale, knowledge of the total cost, including costs incurred by

other federal entities, is vital to the establishment of an appropriate price.

The Use of Estimates

231. The standard places the responsibility on the providing entity to supply the receiving entity

with information on the full costs of non-reimbursed or under-reimbursed inter-entity goods

and services. This is appropriate since only the providing entity is likely to have such

information. Implementation of the standard on full costing should make this requirement

fairly easy for the providing entity to fulfill. If, for some reason, the providing entity cannot or

does not supply the cost information, the receiving entity has no way to recognize the costs

other than through estimation.

232. The Board anticipated this possibility, and requires the receiving entity to use an estimate of

the cost of those goods and services if the actual cost information is not provided. The

estimate must be reasonable and should be aimed at determining realistic costs incurred by

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the providing entity. However, if such a cost estimate cannot be made, the receiving entity

may base the estimate on the market value of the goods or services.

233. Some respondents to the exposure draft stated that the use of estimates would be too

problematic and unreliable and that the receiving entity would not have enough information

to make the estimate. Some were concerned that the use of estimates would cause

arguments between reporting entities over the cost. Others were concerned that some

entities do not have experienced personnel to make such estimates. A few were concerned

about the audit implications of using an estimate.

234. Some respondents expressed concern over the possible use of market values in making the

estimate. Some of these respondents stated that government-type goods and services are

not often produced outside government and, therefore, such market values may not exist.

Others stated that market value does not always bear a direct relationship to true cost or

that market values change too rapidly to be of any use.

235. The Board realizes the problems associated with the use of estimates. However,

implementation of the other managerial cost accounting standards in this statement by the

providing entities should considerably lessen the need for receiving entities to make

estimates of inter-entity costs. The Board also believes that, if the inter-entity costs meet the

recognition criteria established by the standard, and cost information is not received, then

use of a reasonable estimate of cost is preferable to no recognition at all.

236. Estimates are often used in accounting and financial reporting. The recognition of cost

based on estimation is not new and can be reliable so long as the estimate is reasonable

and based on a rational and systematic method. The Board also realizes that the use of

estimation necessarily implies the use of professional judgement. This does not negate the

value of the estimate to users of the financial information and should not present a problem

in relation to audit requirements.

237. The Board realizes that market values may not always be available for many kinds of inter-

entity goods and services. Nevertheless, if such values are available, they can be a good

basis for estimating cost if no other basis can be established. Although market values may

not be directly related to costs of production and they may fluctuate, they may also be

viewed as a fairly reliable guide to the costs an entity might have to incur to obtain inter-

entity goods and services from a non-governmental source. As with the determination of all

estimates, use of market values as an estimation basis requires the use of judgement and

professional care.

238. The Board also realizes that there may be some implementation problems such as

disagreements with providing entities over an estimated cost or with the lack of trained

personnel to make estimates. These problems are of a practical nature and can be resolved

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by management. In that regard, they are not unlike other problems faced when

implementing any new or changed accounting standard such as making changes to

systems and methods and training personnel on the new requirements. Both providing and

receiving entities should work closely with each other to resolve any costing problems just

as they would to solve any non-accounting related situations.

Recognition Criteria

239. It is clear to the Board that the recognition of each and every non-reimbursed or under-

reimbursed inter-entity cost is not possible. The federal government is a very large and

complex entity and it is normal to expect some flow of goods and services between its

activities as a natural and reasonable method of completing missions and objectives. The

Board decided that only certain non-reimbursed or under-reimbursed inter-entity costs

should be addressed. The standard, therefore, includes criteria for recognition which will

limit the application of the standard to only those items deemed most significant and

important.

240. The criteria address the materiality of the non-reimbursed inter-entity cost, whether it is a

part of broad and general support for all entities, and whether it is needed to help determine

a price to non-governmental entities. The materiality criterion considers materiality in the

context of the importance of the item to the receiving entity. Under this criterion, whether an

item of inter-entity cost is recognized depends upon three points. The first of these is

significance to the receiving entity, i.e. whether the item is important enough that

management should be aware of its cost in decision making circumstances. The second is

the degree to which the goods or services are an integral and necessary part of the

receiving entity’s output. The third is the degree to which the good or service can be

matched to the specific receiving entity with reasonable precision.

241. The criterion of broad and general support recognizes that some entities provide support to

all or most other federal entities, generally as a matter of their mission. The costs of broad

and general services should not be recognized by the receiving entity when no

reimbursement has been made. However, if the service is an integral and necessary part of

the receiving entity’s operations and outputs, those costs should be recognized.

242. The criteria also recognize that there are certain cases in which inter-entity costs need to be

recognized because there could be an effect upon a resulting price to a non-governmental

entity. If a federal entity sells outputs to a non-federal entity, it is usually required to recover

the full cost of those goods or services. While cost is not the sole determinant of final price,

knowledge of the actual full cost of production to the government as a whole is necessary to

ensure that the price is appropriately established at a level that will recover all costs.

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243. Most of the respondents to the exposure draft agreed with the recognition criteria. However,

a few were concerned about how the criteria might be interpreted and whether the

standards were too general in nature. The Board realizes that considerable judgement is

required to apply these criteria and notes that the specific facts and circumstances in each

case must be considered. This concern, along with other implementation concerns, led the

Board to make certain decisions about implementation discussed below under

“Implementation Issues.”

Consolidation

244. The standard requires that, when non-reimbursed or under-reimbursed inter-entity costs are

recognized, the receiving entity should recognize the full costs of the goods or services

received as an expense (or asset) and, to the extent that reimbursement is less than full

cost, the difference is to be recognized as a financing source. At the same time, of course,

the providing entity would continue to recognize the full costs of goods and services

provided, and any off-setting reimbursements, in its accounting records. Several

respondents to the exposure draft were concerned about the possibility of “double-counting”

of costs and others raised concerns about the ability to eliminate these transactions in

consolidations.

245. Both the providing entity and the receiving entity are separate reporting entities. Each

should recognize in its accounting records and financial reports the true costs of operations

and any revenues received. The providing entity incurs a cost in providing the goods or

services even though they are sent to another entity. It may also receive a partial payment

or reimbursement. These transactions and events should be reflected in its accounting. The

receiving entity, as a separate reporting entity, should also recognize its total cost of

production. The full cost of non-reimbursed or under-reimbursed goods or services

ultimately contributing to its outputs should be reflected in the costs of production. To the

extent that reimbursement is not made for those costs, the receiving entity is utilizing a

separate source of financing, namely the providing entity. Again, this fact is reflected in the

accounting. The result is that costs recognized but not actually paid are off-set by the

imputed financing source. While the entity’s financial position is not affected, the real costs

of production are reflected.

246. The only possibility for “double-counting” of costs occurs when consolidated financial

reports are prepared for a reporting entity that includes both the providing entity and the

receiving entity. In preparing such statements, the standard calls for elimination of the inter-

entity transactions. In effect, this is no different from the elimination of transactions for which

full reimbursement has been made. The only additional transaction to be eliminated is the

recognition of the imputed financing source by the receiving entity. The recognition of costs

by both the providing entity and the receiving entity and any actual reimbursements would

be eliminated anyway if payment for the inter-entity costs were made.

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247. The Board realizes that identification and tracking of transactions that must be eliminated

for consolidated reports can become complex and difficult. However, this is a practical

implementation problem that management should be able to overcome through the use of

transaction coding or some other identification method. It likely will require changes in

methods and systems currently in use and may require additional training of personnel. The

Board has decided upon a method to ease implementation problems as discussed below.

Implementation Issues

248. As discussed above, the Board realizes that there may be problems in implementing the

standard on inter-entity costing. Recognition of non-reimbursed or under-reimbursed inter-

entity costs is a new concept to federal entities and involves a new way of thinking about

costs. There is concern that application of the standard may be inconsistent among federal

entities. In addition, there could be problems, particularly at first, in developing estimates of

costs; in revising accounting systems and procedures to accommodate these requirements;

and in training personnel to accomplish the task. Furthermore, the Board recognizes the

concern that some have about the elimination of inter-entity cost transactions for

consolidated reporting since the accounting procedures may be complicated.

249. As a result of these problems and concerns, the Board has expressed the need to take a

measured, step-by-step, practical approach to implementation of this standard. Therefore,

the Board has decided that, in implementing the standard, it recommends that OMB, with

assistance from the FASAB staff, should identify the specific inter-entity costs for entities to

begin recognizing and OMB should then issue guidance identifying those costs. OMB

should consider the requirements of the standard including the recognition criteria in

developing the guidance and it should also consider suggestions and information provided

by Treasury, GAO, and other agencies. The Board anticipates the largest and most

important inter-entity costs will be identified first, followed by others as entities gain

experience in the application of the standard. This approach is seen as a practical way to

ensure uniformity in the application and implementation of the standard and to provide time

and experience in overcoming any other practical problems which may arise. Also, the

Board may recommend specific inter-entity costs for recognition in possible future

recommended standards.

Costing Methodology

250. The ED discussed cost accumulation and assignment principles. The ED states that costs

should be accumulated by responsibility segments, and the accumulated costs should be

classified by type of resource such as costs of employees, material, capital, utilities, rent,

etc. The ED states that “The accumulation of costs by responsibility segments does not

mean that each responsibility segment must have its own accounting system. The reporting

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entity may have a centralized accounting system, but the system should be capable of

identifying costs with responsibility segments.” (See ED par. 170)

251. The ED discussed three cost assignment principles: (a) directly tracing costs wherever

feasible and economically practical, (b) assigning costs on a cause-and-effect basis, or (c)

allocating costs on a reasonable and consistent basis. These principles apply to costs of

services provided by a segment to other segments, as well as assigning costs to ultimate

outputs of a segment.

252. The ED then provided brief descriptions of available costing methodologies: activity-base

costing (ABC), job order costing, process costing, and standard costing. The ED pointed out

that these costing methodologies are not mutually exclusive. For example, standard costing

can be used within ABC. ABC and standard costing combined can then be used with either

job order costing or process costing.

253. Most respondents believed that the requirement for cost accumulation by responsibility

segment is appropriate. Some of them stated that costs are accumulated at levels lower

than segments such as cost centers, processes, or activities within a segment. Such

accumulation is consistent with the standard so long as the costs will be aggregated at the

segment level. Some of the respondents stated that the requirement is currently feasible

because their systems are designed to accumulate expenses by segments and by resource

types. Others, however, stated that they must upgrade their general accounting systems in

order to meet the standard requirement.

254. All the respondents agreed with the cost assignment principles. One respondent, while

supporting the principles, stated that the principles should be explicitly ranked by

preference. The Board intended to express an preference among the principles. It stated in

the proposed standard that direct cost tracing should be used “wherever it is feasible and

economically practical.” The Board further stated in the ED that “for the costs that are not

directly traced to outputs, it is preferable that they be assigned to them on a cause-and-

effect basis.” (See ED par. 182) However, for cost-benefit considerations, assigning costs by

allocations cannot be avoided. The Board emphasized that cost allocations should be

performed on a rational basis. It also cautioned that allocations can be arbitrary and thus

may result in distortions. (See ED par. 190) To make the intent of preference more explicit,

the Board has added words to the standard to indicate that the principles are listed by

preference.

255. All the respondents approved the descriptions of available costing methodologies. Some of

them stated that the materials included are clear and provide adequate guidance. The

respondents agreed with the Board’s position that because federal activities are highly

diverse, it is not practical to require a particular costing method for a particular type of

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activity at this time. However, it is appropriate to require that each entity select a costing

methodology that is best suited to its operations and use that methodology consistently.

256. The Board encouraged government entities to study the potential use of ABC in their

operations (ED par. 200). This was well received by the respondents. Eighteen respondents

supported ABC. Most of them said that ABC can be effective when combined with any of the

other costing methodologies. Seven respondents from federal agencies stated that they

believed ABC is appropriate for their activities and were considering using it. In addition, two

respondents stated that the use of standard costing should also be encouraged. The Board

continues to believe that as federal agencies are going through stages in the development

of their managerial costing, more sophisticated and refined costing methods, such as ABC

and standard costing, should be considered and used to minimize arbitrary cost allocations

and to improve full cost information.

257. The Board considered whether the costing methodology section should be recommended

as a concept or a standard. It concluded that it should be a standard. The Board believes

that cost accumulation and assignment principles contained in this section are definitive and

should be followed by federal entities. Only by adhering to the principles and by continuous

refinement of costing methodologies, can reliable full cost information be achieved.

Unused Capacity Costs

258. The ED proposed a standard, which, if adopted, would have required that entities measure

the cost of unused operating capacity and report it as a separate expense. For this purpose,

some entities, such as DoD, must separate operating capacity from “readiness capacities”

which are reserved for war and emergency mobilization rather than normal operations. The

operating capacity can be measured in terms of “practical capacity” which is the maximum

units of output that the available capacity can produce taking the normal stoppage and

interruptions into consideration. Unused capacity is the excess of practical capacity over

actual outputs.

259. A number of respondents appreciated the importance of the proposed requirement. They

stated that capacity cost information would be very useful in improving the cost and capacity

management of federal agencies. Several respondents from the private sector urged that

the proposal be adopted immediately.

260. Most respondents from federal agencies, however, stated that capacity measurements

involve very complex issues and are not feasible to implement at this time. If the proposed

requirement were adopted, agencies would encounter two major types of difficulties. First,

they lack guidance on defining and measuring various types of capacity. For example,

respondents from DoD stated that it is difficult to develop criteria that can be used to

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differentiate defense operating capacity costs from mobilization capacity costs. Civilian

agencies engaging in administrative, policy making, and regulatory activities also indicated

difficulties in defining their practical capacities. Second, respondents of many agencies

stated that they do not have the accounting capability to provide reliable capacity measures.

Without such capability, unused capacity costs could be improperly estimated and the

resulting information could be misleading.

261. Many respondents were also opposed to the proposed standard on the basis of cost-benefit

considerations. They estimated that accounting for capacity costs would require substantial

time and efforts to implement. This would require the use of their limited accounting

personnel and equipment. Respondents from some agencies do not perceive that they have

an over-capacity problem. Thus, it is very uncertain whether capacity accounting results, if

produced, could be used to improve their operations.

262. After considering the responses to the ED, the Board is convinced that it is premature to

recommend capacity accounting either as a standard or as a concept. The Board is aware

that federal agencies have limited personnel and other resources for accounting. They must

devote those limited resources to improving general financial reporting and to establishing

the more fundamental elements of managerial cost accounting. Thus, it would not be cost

beneficial to implement capacity costing at this time.

263. Managing capacity costs is a part of cost management. Although this document does not

recommend a standard for measuring capacity costs, the full cost information required by

the full cost standard will help management in identifying capacity utilization problems.

Some respondents stated that the capacity accounting concepts would be useful to capital

intensive, industrial-type activities and activities that deliver repetitive services that are

measurable in units. The Board is aware that there are on-going research efforts on the

subject in the private accounting communities. Thus, the Board may reconsider capacity

accounting in the future.

Effective Date

264. The Board holds the view that managerial cost accounting has been needed across the

federal government for a long time. Since the standards are quite general and address only

the highest levels of cost accounting, the Board felt that they should be implemented

quickly. The earlier managerial cost accounting is started, the earlier the benefits will be

seen in managing and controlling federal programs and activities. The Board also believes

that an effective date far into the future would not serve to quickly change the government’s

tendency to neglect cost accounting. Therefore, in the exposure draft, the effective date was

set for fiscal periods beginning after September 30, 1995 (i.e., beginning in fiscal year

1996).

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265. A majority of respondents to the exposure draft commented that this date was too early and

said that they foresee problems with implementation at September 30, 1995. Many reasons

were given for a delay in implementation. Chief among these were (1) difficulty in obtaining

funding to make necessary changes in financial systems before September 30, 1995, (2) a

lack of trained accounting personnel and equipment, and (3) a need for time to develop or

modify appropriate cost accounting methodologies and systems and develop management

awareness and support. Respondents suggested implementation dates ranging from one to

five years after the fiscal year 1996 date given in the exposure draft.

266. The Board recognized the validity of the concerns of many respondents over funding,

training, and development of costing activities. However, it also recognized that federal

agencies must be able to develop cost information very soon to meet the requirements of

the GPRA. It also noted that reporting entities do not have to possess sophisticated cost

accounting systems to meet the requirements in these standards. Federal agencies can

take a gradual approach to the development of cost systems, if necessary, while developing

basic cost information through other means in the short term.

267. Nevertheless, the Board agreed that the implementation date in the exposure draft may be

a problem for many federal agencies since cost accounting is relatively new to most of them

and the recommended implementation date is very near. The Board decided, therefore, to

delay the implementation date by one additional year and make the standards effective for

periods beginning after September 30, 1996, with earlier implementation encouraged.

Glossary

268 Early on in the development of the managerial cost accounting project, the task force

determined that many problems can result in cost accounting from the use of similar terms

to mean different things. It concluded that the use of consistent cost accounting terminology

is necessary to avoid confusion and mis-communication. Therefore, it recommended that

the Board attach a glossary to the exposure draft which would define many of the cost

accounting terms used.

269. The Board agreed with this recommendation. It also decided that the establishment of

uniform cost accounting terminology within the federal government is so important that the

glossary should contain not only definitions for terms used in the statement, but also

definitions for other important cost accounting terms even if those terms are not used

directly in the text of the statement. This glossary would serve as the beginning of a uniform

and consistent cost accounting terminology for use within the federal government.

270. Comments were received from only one respondent to the exposure draft concerning the

glossary. That respondent did not suggest changing any of the definitions provided in the

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glossary, but only suggested some additions. The Board decided that the glossary is

sufficient for the time being and should be retained in the final statement as an appendix.

However, it also decided that it may issue additions to the glossary at a later date as more

federal agencies gain experience in the development of cost information, and as the need

for additional standard definitions becomes apparent.

Appendix B: Glossary

See Consolidated Glossary in “Appendix E: Consolidated Glossary.”